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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1992 $9,429 $464 $1,886
1993 8,878 1,332 1,776
1994 3,861 –- 772
The issues for decision are:
1. Whether petitioner had unreported income of $35,125 in
1992, $30,247 in 1993, and $16,305 in 1994. We hold that he had
unreported income of $29,123 for 1992, $24,715 for 1993, and
$16,095 for 1994.
2. Whether petitioner is liable for the addition to tax for
failure to file timely under section 6651(a)(1) for 1992 and 1993
and the accuracy-related penalty under section 6662 for 1992,
1993, and 1994. We hold that he is.
Section references are to the Internal Revenue Code as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Marrero, Louisiana, when he filed the
petition.
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Last modified: May 25, 2011