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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).
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Last modified: May 25, 2011