- 2 -
Respondent determined a deficiency of $34,496 in
petitioner’s Federal income tax for the year 2002 and the
additions to tax under sections 6651(a)(1) and 6654(a) in the
amounts of $10,003 and $1,152.75, respectively.
Prior to trial, the parties agreed to a deficiency in the
amount of $12,642.2 The remaining issues for decision are
whether petitioner is liable for the additions to tax under
sections 6651(a)(1) and 6654(a).
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Mountlake Terrace, Washington.
Petitioner is a real estate agent who specialized in what he
described as “manufactured home parks and RV parks”. More
specifically, this is a phase or aspect of commercial real estate
in which the agent specializes in real estate transactions
representing either buyers or sellers of parks or tracts of land
that are adapted as a location for manufactured homes and/or
recreational vehicles (RVs). The customary practice is that the
entire park is owned by a landlord and lots or spaces in the park
are designated and leased for manufactured homes or RVs. Each
lot is provided with the necessary utilities. The individual
2The settlement is based upon petitioner’s concession that
he earned $103,827 in nonemployee compensation during the year
and $104 in taxable interest income.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011