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deficiency for petitioner’s 2000 taxable year in the amount of
$50,729, and additions to tax pursuant to section 6651(a)(1) and
(2) of $11,414.02 and $4,819.25, respectively, and pursuant to
section 6654 of $2,728.40.1 Subsequently, the parties reached a
partial settlement under which petitioner is liable for a reduced
tax deficiency of $13,170 and is not liable for additions to tax
pursuant to sections 6651(a)(2) and 6654. The remaining issue
for decision is whether petitioner is liable for the addition to
tax pursuant to section 6651(a)(1) for the 2000 taxable year.
FINDINGS OF FACT
At the time this petition was filed, petitioner resided in
St. Cloud, Florida.
During 2000, petitioner received $45 in dividends, $1,009 of
interest income, and $7,735 of gross rental income. Also in
2000, petitioner sold a piece of commercial property for
$293,000, which generated $91,314.90 in cash proceeds and a gain
for petitioner. In addition, petitioner engaged in numerous
stock sales and received proceeds totaling $176,717.
In 2001 petitioner went to an Internal Revenue Service (IRS)
office in Paramus, New Jersey, for help filling out his tax
return and was instructed to call a toll-free phone number
because in person help was not available for Form 1040 Schedule
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year in issue.
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Last modified: May 25, 2011