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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’ Federal
income tax of $6,276 for 1997, an addition to tax under section
6651(a)(1) of $113, and an accuracy-related penalty under section
6662(a) of $1,255. After concessions by petitioners,1 the issues
for decision are: (1) Whether petitioners received $27,330 of
unreported income; (2) whether petitioners are liable for an
addition to tax under section 6651(a)(1); and (3) whether
petitioners are liable for an accuracy-related penalty under
section 6662(a).
Respondent also determined that petitioners are not entitled
to certain miscellaneous itemized deductions claimed on Schedule
A, Itemized Deductions. These adjustments are computational, and
petitioners have not disputed them; therefore, we need not
separately address them. Respondent also determined that
petitioners are entitled to an additional deduction of $289 for
one-half of the self-employment tax determined in the
adjustments.
1 Petitioners concede that they failed to report $2,610 of
income received by petitioner Vanessa Smith (Mrs. Smith) from
“Off The Field Productions” in 1997, and that they filed their
1997 return on May 14, 1998, and, therefore, did not timely file.
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