- 7 - addition to tax under section 6651(a)(1) if such addition is determined by the amount of tax shown on the taxpayer’s return. See secs. 6665(b), 6201(a)(1); Meyer v. Commissioner, 97 T.C. 555, 559 (1991). The summary assessments described above are assessments that are not subject to the deficiency procedures and are not within the jurisdiction of this Court. Meyer v. Commissioner, supra at 560. The amount shown as tax by petitioner on her first amended return does not constitute a deficiency within the meaning of section 6211(a). Wilson v. Commissioner, 118 T.C. 537 (2002); 301.6211-1(a), Proced. & Admin. Regs. Further, an addition to tax under section 6651(a)(1) is not subject to the deficiency procedures if such addition is determined by the amount of tax shown on the taxpayer’s return. Meyer v. Commissioner, supra at 562. The addition to tax of $6,570.68 that respondent determined under section 6651(a)(1) was computed by reference to the tax shown by petitioner on her delinquently filed amended return; thus, pursuant to section 6665(b), the addition to tax is not attributable to a deficiency as defined in section 6211. See Estate of Forgey v. Commissioner, 115 T.C. 142, 146-148 (2000); Meyer v. Commissioner, supra at 559-563. Since we have determined above that the amount of tax shown on the amended return is not a deficiency and the sectionPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011