- 2 - 6654(a) of $122.93.1 After a concession,2 the sole issue remaining before the Court is petitioner’s claim that the notice of deficiency for the taxable year 2000 received from respondent is invalid because of the inclusion of royalty income from Warner Chappell Music, Inc. (Warner Chappell). Petitioner asserts that the Form 1099-MISC from Warner Chappell is invalid because he was not paid the full royalties owed in the year at issue and for prior years by Warner Chappell. Petitioner makes this argument despite having stipulated that he is required under section 61 to include in his gross income, royalties of $16,113 paid to him by Warner Chappell in 2000. We hold that the notice of deficiency issued to petitioner for the 2000 tax year is valid because petitioner has not offered a basis to find error in respondent’s determinations nor any evidence of error. Background The pertinent facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2By answer, respondent conceded the sec. 6651(a)(2) addition to tax. Respondent alleges that on account of this concession of the addition to tax under sec. 6651(a)(2), the addition to tax under sec. 6651(a)(1) should be increased in the amount of .05 percent per month for the first 5 months ($57.15) for a total addition to tax under sec. 6651(a)(1) of $571.50. See sec. 6651(c)(1).Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011