Robert Rodriguez - Page 2

                                         -2-                                          
                                           Additions to Tax                           
          Years    Deficiencies    Sec. 6651(a)(1)   Sec. 6651(a)(2)   Sec. 6654(a)   
          1994       $1,449           $333.50             --               --         
          1995        2,711            669.75             --             $146.01      
          1996        2,573            505.12           $527.57           117.51      
               Section references are to the applicable versions of the               
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
               We decide:                                                             
               1.  Whether petitioner had unreported income of $15,287,               
          $24,471, and $23,701 determined by respondent for the respective            
          years.  We hold he did.                                                     
               2.  Whether petitioner is liable for the additions to tax              
          determined by respondent under section 6651(a)(1).  We hold he              
          is.                                                                         
               3.  Whether petitioner is liable for the addition to tax               
          determined by respondent under section 6651(a)(2).  We hold he              
          is.                                                                         
               4.  Whether petitioner is liable for the additions to tax              
          determined by respondent under section 6654(a).  We hold he is.             
               5.  Whether we shall impose a penalty on petitioner under              
          section 6673 for advancing frivolous and/or groundless claims.              
          We shall impose a penalty of $10,000.                                       
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated.  The parties’ stipulation             
          of facts and the exhibits submitted therewith are incorporated              





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