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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”.
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