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$55,388, and additions to tax pursuant to section 6651(a)(1) and
(2) in the amounts of $7,537.27 and $3,182.40, respectively, and
pursuant to section 6654(a) in the amount of $1,670.89.1 After
concessions,2 the issues for decision are:
(1) Whether petitioner is liable for a deficiency in the
amount of $55,388 for the 2000 taxable year;
(2) whether petitioner is liable for additions to tax under
sections 6651(a) and 6654(a);
(3) whether the Court should impose a penalty, sua sponte,
under section 6673.
FINDINGS OF FACT
The exhibits admitted at trial are incorporated herein by
this reference.3 At the time this petition was filed, petitioner
resided in St. Davids, Pennsylvania.
In 2000, Petitioner received $117,307.32 in wages from
Unisys Corporation (Unisys) and $60,745 in “stocks/bonds sales”
and interest from E Trade Securities, Inc. Unisys withheld
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
2 By answer, respondent conceded the sec. 6651(a)(2)
addition to tax and sought a correlative increase of $837.48 in
the sec. 6651(a)(1) addition to tax, for a total of $8,374.75, on
grounds that the limitations contained in sec. 6651(c)(1) no
longer applied.
3 The parties did not file a stipulation of facts.
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