- 2 - $25,748.40, $15,827, $10,516, and $373,688.60 for the years in issue, respectively. Additionally, respondent determined an addition to tax under section 6651(a) of $93,422.15 for failure to file timely for 1999. At the time of trial, respondent asserted that the correct deficiencies were in the amounts of $1,518,890, $119,466, $78,839, $113,255, and $1,865,426 for 1995, 1996, 1997, 1998, and 1999, respectively, with accuracy-related penalties under section 6662(a) of $303,778, $23,893, $15,768, $22,651, and $373,085 for the years in issue, respectively. The correct addition to tax under section 6651(a) for failure to file timely in 1999 was recomputed as $93,271. After concessions by the parties, the issues for decision are: (1) Whether petitioner, a cash basis taxpayer, must report the damages received under a release and settlement agreement into which he entered with the State of Texas, and, if so, what amounts must be reported as taxable income; (2) whether deductions that petitioner substantiated are allowable under section 162 or 212; (3) whether respondent may amend the answer to include petitioner’s attorney’s fees in his reportable gross income; (4) whether petitioner is liable for section 6662(a) accuracy-related penalties for each of the years in issue; andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011