- 2 -
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)1 Sec.6654(a)
1996 $30,520 $6,867.00 50% of the $1,624.46
interest on
$7,019.60
1997 27,011 6,077.47 50% of the 1,455.14
interest on
$4,591.87
1998 35,140 7,906.50 50% of the 1,594.90
interest on
$3,865.40
1 Respondent concedes that petitioner is not liable for
additions to tax under sec. 6651(a)(2) for 1996-98.
After concessions, the issues for decision are:1
1. Whether petitioner may deduct margin interest of
$1,738.04 in 1996, $1,844.25 in 1997, and $3,764.40 in 1998. We
hold that she may to the extent discussed below.
2. Whether petitioner is liable for the addition to tax for
failure to file under section 6651(a)(1) for the years in issue.
We hold that she is.
3. Whether petitioner is liable for the addition to tax for
failure to pay estimated tax under section 6654(a) for the years
in issue. We hold that she is not.
Section references are to the Internal Revenue Code as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
1 The parties settled all issues related to unreported
income for the years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011