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In separate notices of deficiency, respondent determined the
following deficiencies and additions to tax for petitioner’s 2001
and 2002 tax years:
Year Deficiency Sec. 6651(a)(1) Sec. 6654
2001 $13,060.70 $ 636.18 $ 55.01
2002 9,988.00 1,925.25 248.80
At trial, respondent filed written motions for imposition of the
penalty under section 6673(a).
The issues for decision are: (1) Whether petitioner is
liable for Federal income taxes for the 2 years in question on
compensation he received from his employer for services he
performed as an employee, for State income tax refunds, and, for
the year 2001, on distributions received from a qualified pension
plan; (2) whether petitioner is liable for the additions to tax
under sections 6651(a)(1) and 6654 for the 2 years in question;
and (3) whether petitioner is liable for the section 6673(a)
penalty for the 2 years before the Court.
At trial, respondent conceded an income adjustment for the
2002 tax year for a State income tax refund of $3,186.
Respondent agreed that petitioner did not claim an itemized
deduction for State income taxes on his 2001 Federal income tax
return; therefore, the refund of $3,186 to him during the year
2002 did not constitute income.
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Last modified: May 25, 2011