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MEMORANDUM OPINION
WHERRY, Judge: This case is before the Court on cross-
motions by the parties for summary judgment pursuant to Rule
121.1 The instant proceeding arises from notices of deficiency
in which respondent determined the following deficiencies and
additions to tax with respect to petitioner’s Federal income
taxes:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1999 $4,107 $427.25 --
2000 9,772 1,908.50 $395.08
After a concession by respondent with respect to 2000, the
recalculated amounts for the deficiency, section 6651(a) addition
to tax, and section 6654 addition to tax for that year are
$6,921, $1,195.75, and $242.81, respectively. The issues for
decision are:
(1) Whether petitioner received taxable income during 1999
and 2000, a portion of which is subject to self-employment tax;
(2) whether petitioner is liable for the section 6651(a)(1)
addition to tax for failure timely to file income tax returns for
each of the years at issue; and
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986 as amended and in effect for the
years in issue, and Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011