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Additions to Tax
Tax Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
1994 $9,759 $1,123.25 -- $202.78
1995 15,074 2,313.25 -- 466.64
1996 16,418 2,474.33 To be determined 553.26
1997 19,555 3,108.83 To be determined 705.14
1998 10,778 1,149.75 To be determined 204.99
By amended answer, respondent asserted increased deficiencies
attributable to nonemployee compensation that petitioner
allegedly received from The Louisville Chorus, Inc. (Louisville
Chorus), in amounts of $24,000 and $22,400 in 1995 and 1996,
respectively, and associated additions to tax pursuant to
sections 6651(a)(1) and 6654.
The issues for decision are: (1) Whether petitioner is
liable for deficiencies as determined in the notice of
deficiency, (2) whether petitioner is liable for increases in
deficiencies as alleged in respondent’s amended answer, (3)
whether petitioner is liable for additions to tax under sections
6651(a)(1) and 6654(a) for each year at issue,2 and (4) whether
we should grant respondent’s motion to impose sanctions pursuant
to section 6673(a).
Background
The parties have stipulated some facts, which we incorporate
herein by this reference. When he petitioned this Court,
petitioner resided in Louisville, Kentucky.
2 Respondent concedes the determinations under sec.
6651(a)(2).
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Last modified: May 25, 2011