Deborah Carman Goodin - Page 2

                                        - 2 -                                         
          refer collectively to respondent’s motion for summary judgment              
          and respondent’s motion for a penalty as respondent’s motions.)             
          We shall grant respondent’s motions.                                        
               The record establishes and/or the parties do not dispute the           
               Petitioner resided in Garner, North Carolina, at the time              
          she filed the petition in this case.                                        
               On February 11, 2002, respondent issued to petitioner a                
          notice of deficiency (notice of deficiency) with respect to her             
          taxable years 1997, 1998, and 1999.  In that notice of defi-                
          ciency, respondent determined a deficiency in, and additions to,            
          petitioner’s Federal income tax (tax), as follows:                          
                              Additions to Tax                                        
          Year Deficiency     Sec. 6651(f)   Sec. 6651(a)(2) Sec. 6654(a)             
          1997    $14,644       $10,471                           $771                
          1998    5,842         4,162                             262                 
          1999    6,759         4,801                             319                 
               *In the notice of deficiency, respondent stated:                       
               The amount of the addition to tax cannot be determined                 
               at this time, and an addition to tax of 0.5 percent                    
               will be imposed for each additional month, or fraction                 
               thereof, of nonpayment, up to 22.5 percent as provided                 
               by section 6651(a)(2) of the Internal Revenue Code for                 
               the taxable years ended December 31, 1997; December 31,                
               1998; and December 31, 1999.                                           
               Petitioner did not file a petition with the Court with                 

          (Code) in effect at all relevant times.  All Rule references are            
          to the Tax Court Rules of Practice and Procedure.                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011