Alex B. Rhodes, Jr. - Page 2

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                        Additions to Tax                                                 
          Year  Deficiency  Sec. 6651(a)(1)   Sec. 6651(a)(2)  Sec. 6654(a)              
          1998   $29,644        $6,143            $3,549*         $1,227                 
          1999    29,545         6,191             2,064**         1,311                 
                   *  As determined by respondent through June 3, 2001.                  
               **  As determined by respondent through July 29, 2001.                    

               Unless otherwise indicated, all section references are to                 
          the Internal Revenue Code in effect for the years in issue, and                
          all Rule references are to the Tax Court Rules of Practice and                 
          Procedure.                                                                     
               After concessions, the primary issues for decision are as                 
          follows:                                                                       
               (1) Whether wage and investment income received by                        
          petitioner constitutes taxable income;                                         
               (2) Whether petitioner is entitled to business expense                    
          deductions for which petitioner would have been reimbursed by his              
          employer had petitioner requested reimbursement; and                           
               (3) Whether petitioner is liable for additions to tax under               
          sections 6651(a)(1), 6651(a)(2), and 6654(a) for the failure to                
          file Federal income tax returns, for the failure to pay Federal                
          income tax, and for the failure to pay estimated Federal income                
          tax.                                                                           











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