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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $3,536 $738.75 $154.66
1998 1 2,119 1 526.75 --
1999 2,794 674.00 129.95
2000 9,027 1,990.25 418.92
1 Includes additional amounts not reflected in the original
notice of deficiency. The Court has jurisdiction to redetermine
such increased amounts of the deficiency and any addition to tax
if the Secretary makes a claim at the hearing. Sec. 6214(a).
Respondent moved at trial to amend his answer to reflect these
increases, and petitioner did not object.
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
Petitioner petitioned the Court to redetermine the
deficiencies and additions to tax.
We must decide whether:
1. Petitioner had unreported income of $30,372, $21,091,
$25,661 and $51,612 determined by respondent for the tax years
1997, 1998, 1999, and 2000, respectively.
2. Petitioner is liable for the additions to tax determined
by respondent under section 6651(a)(1).
3. Petitioner is liable for the additions to tax determined
by respondent under section 6654(a).
4. A penalty shall be imposed on petitioner under section
6673 for advancing frivolous and/or groundless claims.
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Last modified: May 25, 2011