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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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