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additions to tax under sections 6651(a)(1)1 and 6654(a) for 1997,
1998, 2000, and 2001 (the years in issue) as follows:
Tax year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $87,669 $19,884.75 $4,207.05
1998 118,109 27,576.00 5,007.64
2000 63,621 14,259.00 3,007.48
2001 37,781 7,726.75 1,204.64
On January 26, 2004, we received and filed petitioner’s
petition for redetermination of the deficiencies for the years in
issue. Petitioner resided in Bronx, New York, when his petition
was filed. In his petition, petitioner argued that respondent’s
calculation of petitioner’s capital gains and losses was
incorrect.2
We set petitioner’s case for trial during our October 25,
2004, New York, New York, trial session, and mailed him a notice
setting case for trial and a standing pretrial order, dated May
19, 2004. The standing pretrial order required the parties to
1All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
2In the notice of deficiency, respondent also determined
that petitioner received unreported income from wages, interest,
dividends, partnerships, real estate, and nonemployee
compensation. Respondent granted petitioner the standard
deduction for all 4 years in issue and determined that petitioner
was liable for a self-employment tax on his nonemployee
compensation for 1998. Respondent also adjusted petitioner’s
personal exemption for each year to reflect the increase in
petitioner’s adjusted gross income. Petitioner did not contest
these adjustments in his petition, and, consequently, except for
computational adjustments, we deem these adjustments conceded.
See Rule 34(b)(4).
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