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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
1995 $78,117 $16,573.25 $0 $3,412.62
1996 9,857 642.83 714.25 301.28
1997 41,120 8,802.00 9,780.00 2,091.52
In an amendment to answer (respondent’s amendment to an-
swer), respondent alleged increases of $71.42 and $1,478 in the
additions to tax under section 6651(a)(1) for 1996 and 1997,
respectively.2
The issues remaining for decision are:3
(1) Did petitioner operate during each of the years at issue
a sole proprietorship engaged in the business of selling jewelry
and certain other items? We hold that he did.
(2) Does petitioner have unreported Schedule C net profit
for each of the years at issue in the amount that respondent
determined in the notice? We hold that he does.
(3) Is petitioner’s filing status for each of the years at
issue married filing separately? We hold that it is.
1All section references are to the Internal Revenue Code
(Code) in effect for the years at issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
2In respondent’s amendment to answer, respondent conceded
the determinations under sec. 6651(a)(2) for 1996 and 1997 that
respondent determined in the notice of deficiency (notice) issued
to petitioner.
3In addition to the issues remaining for decision listed
below, there are other questions relating to certain determina-
tions in the notice that are computational in that their resolu-
tion flows automatically from our resolution of the remaining
issues that we address herein.
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Last modified: May 25, 2011