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section 6651(a)(1)1 for failure to file, $2,402.36 under section
6651(a)(2) for failure to pay, and $1,358.88 under section
6654(a) for failure to pay estimated tax. Respondent conceded
that petitioner is not liable for the addition to tax under
section 6651(a)(2) but contends that petitioner is liable for an
increased addition to tax under section 6651(a)(1) of $6,322 for
2000. After concessions by the parties, the issues for decision
are:
1. Whether petitioner’s sale and purchase of mutual fund
shares in 2000 qualifies as a like-kind exchange under section
1031. We hold that it does not.
2. Whether petitioner may carry forward charitable
contribution deductions from 1995 to 2000 in the amount of $977.
We hold that he may not.
3. Whether we have jurisdiction to decide if respondent
erroneously applied a $5,908 overpayment for 1992 to 1979. We
hold that we do not.
4. Whether petitioner is liable for the addition to tax
for failure to file under section 6651(a)(1) of $6,322 for 2000
and the addition to tax for failure to pay estimated tax under
section 6654 for 2000. We hold that he is.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule References
are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011