Gary T. Mackey - Page 2

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               to the addition to tax under sec. 6654, I.R.C.,                        
               determined for 1995.                                                   

               Gary T. Mackey, pro se.                                                
               James E. Archie, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  By notices of deficiency dated September 5,           
          2001 (the notices), respondent determined deficiencies in, and              
          additions to, petitioner’s Federal income taxes for his taxable             
          (calendar) years 1995 through 1999 (the audit years) as follows:            
                                         Additions to Tax                             
          Year  Deficiency  Sec. 6651(a)(1) Sec. 6651(a)(2)   Sec. 6654(a)            
          1995    $34,309      $8,577.25          --        $1,860.32                 
          1996     33,891       --                --             1,803.86             
          1997     45,536    10,634.00            --             2,436.20             
          1998      5,252         605.17     To be determined    240.35               
          1999     23,741     5,340.82       To be determined    1,148.74             
               Pursuant to a stipulation of settled issues filed with the             
          Court, the parties have stipulated: (1) Petitioner’s items of               
          income for 1995, 1996, and 1997, (2) certain items of deduction             
          available to him for such years, (3) that there are no                      
          deficiencies or additions to tax for 1998 and 1999, and (4) that            
          there are overpayments of $2,562.36 and $4.00 for 1998 and 1999,            
          respectively.  Respondent has also conceded the additions to tax            
          under section 6651(a)(1) for 1995 and 1997.  The issues remaining           
          for decision are whether: (1) Respondent’s actions and                      
          communications in the wake of assessments made but subsequently             





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