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Additions to tax
Sec. Sec. Sec. Sec.
6653 6653 6653 6653 Sec.
Year Deficiency (b)(1) (b)(2) (b)(1)(A) (b)(1)(B) 6654
1982 1$14,041 $7,021 2 –- –- $1,359
1983 315,785 4 –- 964
7,893 –-
1984 12,953 6,477 5 –- –- 814
1985 27,178 13,589 6 –- –- 1,558
1986 19,911 –- –- $14,933 7 963
1987 5,430 –- –- 4,073 8 294
1 This deficiency is subject to a prepayment credit
adjustment of $73.
2 50 percent of the interest due on $13,968.
3 This deficiency is subject to a prepayment credit
adjustment of $19.
4 50 percent of the interest due on $15,766.
5 50 percent of the interest due on $12,953.
6 50 percent of the interest due on $27,178.
7 50 percent of the interest due on $19,911.
8 50 percent of the interest due on $5,430.
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,1 the issues for decision are:
1In the notice of deficiency dated June 27, 1994, respondent
determined that petitioner: (1) Received unreported interest
income during 1982, 1983, 1984, 1985, 1986, and 1987 of $84,
$290, $22, $114, $110, and $19, respectively; (2) received
unreported income from forgiveness of indebtedness during 1986 of
$3,471; and (3) is liable for self-employment taxes for all years
at issue. Petitioner did not raise these issues in his petition
or at trial. We deem these issues conceded. See Rule 34(b)(4).
Additionally, in his petition petitioner alleged that
respondent erred in determining that petitioner: (1) Is not
entitled to various deductions claimed on Schedule A, Itemized
Deductions, in addition to those allowed by respondent for all
years at issue; (2) is not entitled to head-of-household filing
status under sec. 2(b) for all years at issue; (3) is not
entitled to the child care credit under sec. 21 for all years at
(continued...)
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Last modified: May 25, 2011