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For taxable years 1995 and 1996, respondent determined
deficiencies in petitioner’s Federal income taxes of $11,933 and
$26,947, additions to tax under section 6651(a)(1) of $2,927.50
and $5,347.57, and additions to tax under section 6654(a) of
$637.90 and $1,246.20.
After concessions by both parties, the issues remaining for
decision are: (1) Whether petitioner received a distribution of
$34,107 from The First National Bank of Ogden in 1995; (2)
whether petitioner is entitled to a dependency exemption
deduction for his daughter Amy Mudd in 1996; and (3) whether
petitioner is entitled to a charitable contribution deduction in
1996.1
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. Petitioner resided in
Fort Mitchell, Kentucky, on the date the petition was filed in
this case.
1In his petition, petitioner states that “penalties and
interest are overstated based on actual taxable income.” At
trial, petitioner did not make any further arguments or present
any evidence concerning the additions to tax for failure to file
a timely return under sec. 6651(a)(1), and for failure to make
estimated tax payments under sec. 6654(a). We conclude that
petitioner disputes only the underlying tax deficiencies, not the
applicability of the additions to tax. The correct amounts of
these additions to tax, therefore, will be calculated by the
parties in the Rule 155 computations required in this case.
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