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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6654(a)
1993 $18,904 $1,903.75 $266.45
The issues remaining for decision are:2
(1) Is petitioner entitled to deduct for 1993 certain
claimed charitable contributions? We hold that he is not.
(2) Is petitioner liable for 1993 for the addition to tax
under section 6651(a)(1)? We hold that he is.
(3) Is petitioner liable for 1993 for the addition to tax
under section 6654(a)? We hold that he is.
FINDINGS OF FACT
Most of the facts have been stipulated by the parties and
are so found.
At the time petitioner filed the petition in this case, he
resided in Chicago, Illinois.
During the year at issue, petitioner received wages of
$73,515 from OR Human Resources and other income of $4,280 from
Occupational Medical Care, Inc. However, petitioner did not file
a tax return for that year.
1All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
2Petitioner concedes the determinations in the notice of
deficiency (notice) to increase his income for the year at issue.
Respondent concedes that, instead of the standard deduction
(i.e., $3,100) that respondent allowed petitioner in the notice,
petitioner is entitled to deduct for the year at issue $3,541 of
mortgage loan interest and $1,083 of points paid during that
year.
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Last modified: May 25, 2011