- 2 - Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined deficiencies, additions to tax, and penalties in petitioner’s 1997 and 1998 Federal income taxes as follows: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1997 $7,571 $1,468.25 $2,212.20 1998 24,052 5,341.75 4,288.40 After concessions,1 the issues for decision are: (1) Whether petitioner is entitled to “married filing joint return” filing status for the 1997 taxable year; (2) whether petitioner is liable for additions to tax for failure to file timely returns for the 1997 and 1998 taxable years pursuant to section 6651(a)(1); and (3) whether petitioner is liable for accuracy- 1 With respect to the 1997 taxable year, respondent concedes the issue whether petitioner had unreported capital gain of $5,981, while petitioner concedes that he is not entitled to either the self-employment health insurance deduction of $4,866 or a deduction for Keogh and self-employed SEP and SIMPLE plans of $30,000. With respect to the 1998 taxable year, respondent concedes that petitioner did not have unreported taxable interest income of $81 and unreported capital gain of $26,091 and that petitioner is not liable for a tax deficiency and additional tax under sec. 72(t) resulting from an IRA distribution of $19,908.16. With respect to the 1998 taxable year, petitioner concedes that he had unreported interest income of $80, that he is not entitled to either the self-employment health insurance deduction of $4,987 or the IRA deduction of $2,000, and that he should have filed using the status of “married filing separate return” instead of “head of household”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011