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Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662
1992 $117,034 $29,258 $23,407
1993 361,493 90,373 $5,447
1994 48,973 12,243 2,541
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions,2 the issues for decision are: (1)
Whether petitioner had additional unreported income for 1992,
1993, and 1994, (2) whether petitioner is liable for an addition
to tax pursuant to section 6651(a)(1) for 1992, 1993, and 1994,
(3) whether petitioner is liable for an addition to tax pursuant
to section 6654 for 1993 and 1994, and (4) whether petitioner is
liable for a penalty pursuant to section 6662 for 1992.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in New York, New York.
2 Petitioner concedes that deposits totaling $168,948,
$133,022, and $41,124 in 1992, 1993, and 1994, respectively, are
taxable income to petitioner for 1992, 1993, and 1994,
respectively. Respondent concedes that deposits totaling $3,897,
$3,665, and $3,951 in 1992, 1993, and 1994, respectively, are not
taxable income to petitioner. Additionally, respondent concedes
that petitioner received gifts totaling $10,000 in 1992 and
$19,949 in 1993.
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Last modified: May 25, 2011