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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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Last modified: May 25, 2011