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2000 and $288.17 for 2002. Respondent now contends that, for
2000, petitioner’s income tax deficiency is $5,457 and that he is
liable for additions to tax under section 6651(a)(1) of $874 and
under section 6654 of $175. Respondent concedes that petitioner
is not liable for the addition to tax under section 6651(a)(2)
for 2002 and now contends that he is liable for an increased
addition to tax under section 6651(a)(1) of $1,940.25 for 2002.
The issues for decision are:
1. Whether petitioner had unreported income of $38,858 for
2000 and $55,197 for 2002. We hold that he did.
2. Whether petitioner is liable for the addition to tax for
failure to file under section 6651(a)(1) of $874 for 2000 and
$1,940.25 for 2002. We hold that he is.
3. Whether petitioner is liable for the addition to tax for
failure to pay estimated tax of $175 for 2000 and $288.17 for
2002. We hold that he is.
4. Whether petitioner is liable for a penalty under section
6673 for instituting proceedings primarily for delay and for
maintaining frivolous or groundless positions. We hold that he
is in the amount stated below.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable years in issue.
Rule references are to the Tax Court Rules of Practice and
Procedure.
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