Gary T. Mackey - Page 3

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          abated with respect to the audit years preclude him from                    
          prevailing with respect to the deficiencies and additions to tax            
          remaining at issue, (2) amounts petitioner remitted at the time             
          of filing extension requests for 1996 and 1997 reduce the                   
          deficiencies determined for those years, and (3) respondent has             
          satisfied his burden of production under section 7491(c) with               
          respect to the section 6654(a) additions to tax remaining at                
          issue.                                                                      
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the years at issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                     Background                                       
               The parties have filed a stipulation of facts and have                 
          submitted this case without trial pursuant to Rule 122.  The                
          stipulation of facts, with accompanying exhibits, is incorporated           
          herein by this reference.  We have inferred additional facts from           
          uncontested portions of the parties’ submissions.  We shall set             
          forth only such facts as are necessary to understand our                    
          discussion and conclusion.                                                  
               At the time he filed the petition, petitioner resided in               
          Arlington, Texas.                                                           
               Although he requested an extension of time to file his                 
          Federal income tax return for each of the audit years, petitioner           






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