- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011