Edward Kazuo Ozaki - Page 2

                                        - 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).                                                                    




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