- 2 - 2. Held, further, modifications to the deficiency determinations for 1997-99 required in order to correct computational errors. 3. Held, further, R’s penalty against P for 1997 sustained, in part, under sec. 6662, I.R.C. Alvin S. Kanofsky, pro se. Frank J. Jackson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency dated April 19, 2004 (the notice), respondent determined deficiencies in petitioner’s Federal income tax and an accuracy-related penalty as follows: Tax Year Ending Penalty Dec. 31 Deficiency Sec. 6662(a) 1996 $14,506 --- 1997 15,437 $3,087.40 1998 10,078 --- 1999 716 --- 2000 2,970 --- By the petition, petitioner assigns error to respondent’s deficiency determinations for all years and his penalty determination for 1997. After concessions,1 the issues for decision are whether petitioner is (1) entitled to deductions he 1 Petitioner concedes respondent’s inclusion in income of (1) $70 of unreported interest for both 1999 and 2000, and (2) an unreported State tax refund of $30 for 1999.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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