- 2 - Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654 1996 $10,679 $2,402.78 1 $568.41 1997 3,927 883.58 1 210.09 1998 5,084 1,143.90 1 232.62 1999 5,180 1,165.50 1 262.00 1In the notices of deficiency, respondent listed these amounts as “To Be Computed”. After concessions,1 the issues for decision are: (1) Whether petitioner must include in gross income amounts received as compensation for services and as interest during the years in 1The notices of deficiency contain a number of adjustments for the years in issue. Respondent determined that for all years petitioner was required to include in gross income amounts received as compensation for services and as interest. Respondent also determined that petitioner was entitled to deductions in 1997, 1998, and 1999 for health insurance premiums paid, and that petitioner was entitled to deductions in all years in issue for certain expenses claimed on Schedule C, Profit or Loss From Business. Respondent further determined that for all years in issue petitioner was entitled to the standard deduction based on married filing separately status and to one personal exemption for himself. Finally, respondent determined that petitioner was liable for additions to tax under secs. 6651(a)(1) and (2) and 6654 for all years in issue. In the stipulation of facts and the supplemental stipulation of facts, the parties resolved most of the adjustments contained in the notices of deficiency and also agreed to other adjustments in petitioner’s favor that were not contained in the notices. Specifically, respondent conceded that petitioner is entitled to: (1) An additional exemption deduction for his wife; (2) additional self- employment health insurance deductions; and (3) various itemized deductions (relating to property taxes, charitable contributions, medical expenses other than health premiums, and a tax preparation fee) rather than the standard deductions determined in the notices of deficiency. On brief, respondent concedes that petitioner is not liable for the additions to tax under secs. 6651(a)(2) and 6654 for the years in issue. The parties shall take the agreements contained in the stipulations and respondent’s concessions into account in the Rule 155 computation.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011