Douglas G. Turnidge - Page 2

                                                                  - 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.                                                                                                                  




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