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liable under section 6651(a)(2) for additions to his 1989, 1990,
1991, and 1993 taxes in amounts to be determined. In answering
petitioner’s petition in docket No. 9582-04, respondent conceded
that petitioner is not liable for the section 6651(a)(1) and (2)
additions to tax determined for 1989.
In docket No. 9703-04, Hickey petitioned the Court on
June 10, 2004, to redetermine respondent’s determination of the
following deficiencies, additions to tax, and penalties:
Additions to tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6663
1992 $10,728 $0 $0 $8,046
1993 2,674 165 318 2,006
Respondent reflected this determination in a single notice of
deficiency issued to Hickey on March 25, 2004. Respondent also
determined in the notice of deficiency that Hickey is liable
under section 6651(a)(2) for an addition to her 1993 tax in an
amount to be determined. In answering Hickey’s petition in
docket No. 9703-04, respondent conceded that she is not liable
for the section 6663 penalties determined for 1992 and 1993 and
alleged as to 1992 that she is liable for a $2,145.60 accuracy-
related penalty under section 6662(a) and (d) for substantial
understatement.
In docket No. 10519-04, Hickey petitioned the Court on
June 21, 2004, for relief under section 6015 from joint liability
for any amount that she is determined to be liable in docket No.
9703-04. On March 25, 2004, the Commissioner had issued to
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