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Additions to tax
Year Deficiencies Sec. 6651(a)(1)
1998 $41,022 $10,255.50
2000 27,094 6,773.50
All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the years at issue.
Background
On July 10, 2003, we filed petitioner’s timely petition for
redetermination with respect to his 1998 and 2000 taxable years.1
Petitioner resided in Thorofare, New Jersey, when the petition
was filed in this case. The petition contains the following
allegations of error:2
Virtually all of the taxes shown should be excluded or
dismissed. There were procedural and legal issues in
the handling of my case that were never properly
addressed. These relate specifically to the
calculation of depreciation expense.
This case was first set for trial during the Court’s
1Petitioner also sought a redetermination concerning 1997,
but no notice of deficiency for 1997 was attached to the
petition. By order dated Mar. 4, 2005, we directed petitioner to
show cause by Mar. 18, 2005, why his claim for relief with
respect to 1997 should not be dismissed for lack of jurisdiction.
Petitioner did not respond. By order dated Mar. 28, 2005, we
dismissed petitioner’s claim regarding 1997 for lack of
jurisdiction.
2The petition does not contain a specific allegation
assigning error to respondent’s determination that petitioner is
liable for additions to tax under sec. 6651(a)(1). Because
petitioner did not contest the additions to tax in the petition,
they are deemed conceded in accordance with Rule 34(b)(4).
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Last modified: May 25, 2011