- 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.
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