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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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