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is not reviewable by any other court, and this opinion should not
be cited as authority.
Respondent determined deficiencies in petitioner’s Federal
income tax for the years 2001 and 2002 in the amounts of
$7,017.50 and $4,962.65, respectively. Respondent also
determined an addition to petitioner’s Federal income tax for
2002 under section 6651(a)(1).2 Petitioner timely filed a
petition with the Court. The issues for decision are whether
petitioner is a qualified personal service corporation subject to
a flat tax rate and whether petitioner is liable for the
additions to tax under section 6651(a)(1).
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ oral
stipulations at trial and accompanying exhibits.
At the time the petition was filed, petitioner’s principal
place of business was Brooklyn, New York.
Regina Felton (Ms. Felton) is an attorney who has been
engaged in the practice of law since 1978. In 1987, Ms. Felton
2 The notice of deficiency determined an addition to tax
for 2002 under sec. 6651(a)(1) of $1,414.36. However, this
appears to comprise $1,116.60 allocable to sec. 6651(a)(1),
failure to file, and $297.76 allocable to sec. 6651(a)(2),
failure to pay. Because the sec. 6651(a)(2) addition was not
determined in the notice of deficiency and is not properly before
the Court, we decide only the issue of the addition to tax
imposed under sec. 6651(a)(1).
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