- 2 - 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 subsequentlyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011