- 2 - Respondent issued petitioner three separate notices of deficiency, each dated June 6, 2003, determining that petitioner was liable for deficiencies in Federal income taxes and additions to tax in the following amounts for the 1997, 1998, and 1999 taxable years: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654 1997 $30,884$2,905.88 To be determined $1,371.69 1998 29,573 3,044.03 To be determined 934.42 1999 11,330 100.00 To be determined 539.47 Petitioner filed a timely petition with the Court in which he does not dispute the deficiencies determined, but only disputes the additions to tax. Respondent did not file an answer to the petition.1 At the time of trial, respondent filed a pretrial memorandum wherein he asserted increased deficiencies and increased additions to tax. The parties filed a stipulation of facts wherein petitioner agreed to the increased deficiencies and increased additions to tax under section 6654 and also agreed that if the failure to file tax returns for the 1997, 1998, and 1999 taxable years was not due to reasonable cause, then the 1 Petitioner elected to have his case conducted as a small tax case under the proceedings of sec. 7463. For the election to be valid, the “amount of the deficiency placed in dispute” may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987). Taking into account petitioner’s concessions in the present case, we concur with his election to conduct his case as a small tax case because the amount placed in dispute for each of the years in issue does not exceed $50,000.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011