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Additions to tax
Year Deficiency Sec.1 6651(a)(1) Sec. 6654(a)
1996 $3,326 $831.50 $133.04
1 Throughout this opinion and unless otherwise
indicated, all section references are to the
Internal Revenue Code in effect for the taxable
year in issue.
After concessions by the parties,1 the issues are as
follows:
(1) Whether petitioner’s military retirement pay is
includable in gross income. We hold that it is.
(2) Whether petitioner’s Social Security benefits are
includable in gross income pursuant to section 86. We hold that
they are.
(3) Whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failure to file. We hold that he
is.
(4) Whether petitioner is liable for an addition to tax
under section 6654(a) for failure to pay estimated tax. We hold
that he is.
1 Petitioner concedes that he received interest income in
the amount of $10 from Capital One Federal Savings Bank (Capital
One).
Respondent concedes that the notice of deficiency
erroneously treated a deduction for a personal exemption as a
positive (i.e., upward) adjustment to petitioner’s income. After
recomputation to correct this error, the amounts of the
deficiency and the additions to tax are as follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1996 $2,561 $576 $79
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Last modified: May 25, 2011