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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
2000 $76,851 $10,472.40 $4,421.68 $2,322.15
In respondent’s answer, respondent conceded the addition to
tax under 6651(a)(2) for petitioner’s taxable year 2000 and
alleged an increase for that year in the addition to tax under
section 6651(a)(1).
The issues remaining for decision are:
(1) Are certain payments that petitioner received from
Gardner, Carton & Douglas (GC&D or firm) during 2000 excludable
under section 104(a)(2) from petitioner’s gross income for that
year? We hold that they are not.
(2) Is petitioner liable for 2000 for the addition to tax
under section 6651(a)(1)? We hold that she is.
(3) Is petitioner liable for 2000 for the addition to tax
under section 6654(a)? We hold that she is to the extent stated
herein.
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
Petitioner resided in Lanham, Maryland, at the time she
filed the petition in this case.
During the period that began around 1995 and that ended on
1All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011