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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
1996 $62,718 $13,661.55 $3,946.67 $3,164.00
1997 42,929 3,893.63 2,941.85 2,296.75
The issues remaining for decision are:2
(1) Is the net profit for each of the years at issue from
petitioner’s washing machine repair business subject to tax? We
hold that it is.
(2) Is the pension income that petitioner received during
1997 subject to tax? We hold it is.
(3) Is petitioner liable for 1997 for the 10-percent addi-
tional tax under section 72(t)(1) with respect to the pension
income that he received during that year? We hold that he is.
(4) Is petitioner liable for each of the years at issue for
an addition to tax under section 6651(a)(1)? We hold that he is.
(5) Is petitioner liable for each of the years at issue for
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2Before trial, the parties filed a stipulation of settled
issues setting forth their agreement as to the disposition of
certain determinations in the notice of deficiency (notice) that
respondent issued to petitioner for the years at issue. After
trial, respondent conceded the determinations in the notice under
sec. 6651(a)(2).
In 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, from the parties’ stipulation of
settled issues, and from respondent’s concession of the determi-
nations under sec. 6651(a)(2).
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Last modified: May 25, 2011