- 2 -
All section references are to the applicable Internal Revenue
Code, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions,1 the issues for decision are: (1)
Whether petitioner is liable for the deficiencies determined by
respondent for 1999, 2000, and 2001 in excess of the amounts he
conceded; (2) whether petitioner is liable for the addition to
tax pursuant to section 6651(a)(1) for 1999, 2000, and 2001; (3)
whether petitioner is liable for the addition to tax pursuant to
section 6654(a) for 2000 and 2001; and (4) whether to impose a
penalty pursuant to section 6673.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, petitioner resided in Arlington, Texas.
I. Notices of Deficiency and Forms 1040
On January 14, 2004, respondent issued petitioner separate
notices of deficiency for 1999, 2000, and 2001. After receiving
the notices of deficiency for 1999, 2000, and 2001, on January
1 Respondent concedes that (1) Texas community property
laws are applicable to petitioner, (2) petitioner’s income listed
in the notice of deficiency must be reduced in accordance with
Texas community property laws, (3) petitioner’s filing status is
married filing separately, (4) no addition to tax pursuant to
sec. 6654(a) is due from petitioner for 1999, and (5) petitioner
incurred net losses on his stock transactions for 2000 and 2001.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011