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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined the following deficiencies in
petitioner's Federal income taxes and additions to tax for
failure to file timely:
Addition to Tax1
Year Deficiency Sec. 6651(a)(1)
1998 $5,354 $1,272
1999 4,577 793
2000 7,064 1,357
1Figures are rounded to the nearest dollar.1
After a concession,1 the issues for decision are whether:
(l) Respondent is estopped from asserting a deficiency against
petitioner for 1999; (2) petitioner is required to include in
income a reward received from the Internal Revenue Service (IRS)
during 1998; (3) petitioner is entitled to deductions on Schedule
C, Profit or Loss From Business, for 1998, 1999, and 2000 in
excess of those allowed by respondent; and (4) petitioner is
liable for additions to tax for failure to file timely his 1998,
1999, and 2000 Federal income tax returns.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
1Respondent concedes that petitioner is entitled to a
deduction for depreciation expenses of $2,834 for 2000.
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