Thomas S. Russo - Page 3




                                        - 2 -                                         
               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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