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By notice of deficiency, respondent determined deficiencies
in petitioners’ Federal income tax, additions to tax under
section 6651(a), and accuracy-related penalties under section
6662 as follows:
Additions to Tax/Penalties
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a) 6662(h) 6662(e) 6662(d) 6662(c)
1994 $15,535 $2,264 $6,214 $3,107 $3,107 $3,107
1995 8,837 507 3,415 1,707 1,707 1,707
Petitioners have conceded that they are liable for
deficiencies of $15,535 for 1994 and $8,837 for 1995. The
remaining issues for decision are: (1) Whether petitioners are
liable for additions to tax under section 6651(a) for filing
their income tax returns after the due dates and (2) whether
petitioners are liable for accuracy-related penalties under
section 6662.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Other facts are
established by admission. Neither petitioners nor any witnesses
testified on petitioners’ behalf. When they filed their
petition, petitioners resided in Scottsdale, Arizona.
Petitioner James Jaroff was employed as a computer
programmer for the Software Works! of L.A. and Allied Packaging
Corp. in 1994 and for Allied Packaging Corp. in 1995. Petitioner
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