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Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1995 $53,053 $11,888.25 $1,176.73
1996 46,471 11,617.75 2,473.43
1997 47,946 11,986.50 2,565.14
1998 65,711 16,427.75 3,006.82
1999 45,918 11,479.50 2,222.26
2000 30,873 7,718.25 1,649.08
Respondent determined the following deficiencies and additions to
tax with respect to petitioner Donnie J. Rinn’s Federal income
taxes:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1995 $16,752 $2,813.00 $538.13
1996 14,176 3,544.00 754.53
1997 14,622 3,655.50 782.30
1998 21,235 5,308.75 971.68
1999 13,443 3,360.75 650.60
2000 7,671 1,917.75 409.72
The issue for decision is whether petitioners are liable for
the deficiencies and additions to tax that respondent
determined.1
Unless otherwise indicated, section references are to the
Internal Revenue Code (Code), as amended, and Rule references are
to the Tax Court Rules of Practice and Procedure.
1 Respondent also determined additions to tax pursuant to
sec. 6651(a)(2) for petitioners’ 1996 through 2000 tax years for
failure to timely pay tax shown on a return. Respondent has
conceded these additions to tax. Cf. Spurlock v. Commissioner,
T.C. Memo. 2003-124.
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Last modified: May 25, 2011