-2-
Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
2000 $103,811 $21,728.92 $12,071.62 $5,150.77
The issues remaining for decision are:
(1) Is petitioner entitled to deduct for 2000 a theft loss
under section 165? We hold that he is not.
(2) Is petitioner liable for 2000 for the addition to tax
under section 6651(a)(1)? We hold that he is.
(3) Is petitioner liable for 2000 for the addition to tax
under section 6654(a)? We hold that he is to the extent stated
herein.
FINDINGS OF FACT
Most of the facts have been stipulated by the parties and
are so found.
At the time petitioner filed the petition in this case, he
resided in Annapolis, Maryland.
On May 24, 2000, petitioner and June Davis (Ms. Davis), his
wife, executed a contract (custom house contract) with Mona
Builders & Developers, Inc., (Mona Builders). That contract
provided in pertinent part:
ARTICLE ONE -- THE WORK
MONA BUILDERS & DEVELOPERS, INC. [Mona Builders] shall
perform all work required by the Contract Documents for
1All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011