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Pursuant to notices of deficiency dated January 22, 2001,
respondent determined the following deficiencies in, and
additions to, petitioner’s Federal income tax:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654(a)
1996 $15,479 $3,174.53 $3,103.98 $742.87
1997 11,741 2,271.10 1,618.56 531.55
1998 25,018.20 5,017.54 2,230.02 1,006.60
After the mailing of the notices of deficiency and before
the filing of the petition, petitioner filed Federal income tax
returns for 1996, 1997 and 1998 indicating taxes for those years
of $9,147, $7,099 and $35,119, respectively. After the filing of
the petition, respondent filed an answer alleging that the
correct amounts of deficiencies for 1996, 1997 and 1998 are
$9,147, $7,099 and $35,119, the amounts shown on the tax returns
filed by petitioner. In the answer, respondent further asserted
that petitioner is liable for additions to the tax for each of
the taxable years 1996, 1997 and 1998. Also in the answer,
respondent asserted that for 1998 the addition to tax pursuant to
section 6651(a)(1) should be $5,017.54, the amount initially
determined by respondent, plus an increase of $2,130.04 and that
for 1998, the addition to tax pursuant to section 6651(a)(2)
should be 0.5 percent of the amount of income tax shown on the
1998 return ($35,119), commencing on the due date of the
petitioner’s return and accruing for each month or fraction
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