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Respondent determined a deficiency in petitioner’s 2000
Federal income tax and additions to tax as follows:
Additions to Tax
Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) 6654(a)
$6,555 $1,417.72 $661.60 $337.35
After concessions,1 the issues for decision are: (1) Whether
petitioner received unreported income of $17,599.12 in wages,
interest, dividends, and gains from the sale of stock for the
2000 taxable year; (2) whether petitioner is liable for an
addition to tax under section 6651(a)(1) of $1,417.72 for the
2000 taxable year; and (3) whether petitioner is liable for an
addition to tax under section 6654(a) of $337.35 for the 2000
taxable year.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
1 Respondent concedes that petitioner is not liable for the
addition to tax under sec. 6651(a)(2). In the notice of
deficiency, respondent determined that petitioner received $1,068
in dividends from Merrill Lynch Pierce Fenner & Smith (Merrill
Lynch). Respondent concedes that petitioner received only $721
in dividends from Merrill Lynch.
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Last modified: May 25, 2011