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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
1998 $2,674 $570.83 $634.25 $121.36
2001 3,514 790.65 298.69 139.05
The issues remaining for decision are:
(1) Should the Court sustain respondent’s deficiency
determination for each of the years at issue? We hold that the
Court should.
(2) Is petitioner liable for each of the years at issue for
an addition to tax under section 6651(a)(1)? We hold that he is.
(3) Is petitioner liable for each of the years at issue for
an addition to tax under section 6654(a)? We hold that he is.
FINDINGS OF FACT
Most of the facts have been deemed admitted pursuant to Rule
90(c). Certain other facts have been stipulated and are so
found.
At the time he filed the petition in this case, petitioner’s
mailing address was in Magnolia, Kentucky.
During 1998, petitioner received a total of $15,406 in wages
from the companies indicated below:
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011