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$12,392 in petitioner’s Federal income tax for 2002, and a
$2,478.40 penalty under section 6662(a). Unless otherwise
indicated, all section references are to sections of the Internal
Revenue Code in effect for 2002, and all Rule references are to
the Tax Court Rules of Practice and Procedure. Henry R.
Broderick, and his spouse, Denise F. Broderick, filed a joint
Federal income tax return for 2002, and respondent’s notice of
deficiency is addressed to both of them. However, only Henry
(petitioner) filed a petition in response thereto. Petitioner
resided in New Jersey when he filed his petition.
There is a confused state of the record in this case; some
of the facts have been stipulated and are so found.
Petitioner is the sole shareholder of Woodside Consulting,
Inc. (Woodside), a corporation which petitioner considers to be
taxable as a small business corporation consistent with
subchapter S of the Internal Revenue Code. For the taxable year
2002, Woodside filed an untimely tax return on Form 1120S, U.S.
Income Tax Return for an S Corporation. The return reflects that
for 2002, Woodside had gross receipts of $2,956 and an ordinary
loss of $29,000. Petitioner’s items from Woodside are
essentially uncoordinated with his Form 1040, U.S. Individual
Income Tax Return, items; so we have dealt with both returns as a
single unit. Respondent concedes that petitioner erroneously
indicated on Schedule E, Supplemental Income and Loss, of his
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