- 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