- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011