- 2 - Additions to Tax Sec. Sec. Sec. Year Deficiency 6651(a)(1)1 6651(a)(2) 6654(a) 1994 $9,397 $1,135.00 --- $276.79 1995 12,201 1,484.08 --- 361.11 1996 12,247 1,406.70 $1,563.00 349.34 1997 14,220 1,593.45 1,628.86 395.91 1998 15,372 1,722.60 1,301.52 386.40 1999 21,621 1,235.03 603.79 205.78 2000 20,063 1,471.95 327.10 270.37 The issues remaining for decision are:2 (1) Is petitioner liable for the addition to tax under section 6651(a)(1) for each of the years at issue? We hold that he is. (2) Is petitioner liable for the addition to tax under section 6654(a) for each of the years at issue? We hold that he is. FINDINGS OF FACT Most of the facts have been deemed established pursuant to the Court’s Order under Rule 91(f) dated February 26, 2003. At the time petitioner filed the petition in this case, he 1All section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2The only determinations in the notices of deficiency for the years at issue that petitioner disputes relate to the addi- tions to tax under secs. 6651(a)(1) and (2) and 6654(a). Respon- dent concedes the determinations under sec. 6651(a)(2). We conclude that petitioner has abandoned contesting any remaining determinations in the notices of deficiency for the years at issue other than the determinations under secs. 6651(a)(1) and 6654(a).Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011