Kevin Ryan Robinson - Page 8

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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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