- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011