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production under section 7491(c) with regard to the section
6651(a)(1) additions to tax for 1997, 1998, and 2000 and the
section 6654(a) additions to tax for 1997 and 1998, and
petitioner has not provided any facts that raise any issue as to
his liability therefor.
For the reasons stated, we shall grant partial summary
judgment with regard to the amount of petitioner’s 1997, 1998,
and 2000 income as determined by respondent and with regard to
the applicability of the additions to tax under section
6651(a)(1) for 1997, 1998, and 2000 and section 6654(a) for 1997
and 1998, but we deny summary judgment with regard to
petitioner’s filing status and exemptions for each of the years
in issue.2
An appropriate order will
be issued.
2 Depending on the eventual outcome of the filing status
and exemption issues, the amount of petitioner’s tax deficiencies
and additions to tax may be adjusted from the amounts set forth
in respondent’s notices of deficiency.
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Last modified: May 25, 2011