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Additions to Tax
Year1 Deficiency Sec. 6651(a)(1) Sec. 6654
1998 $16,067 $3,550.25 $634.33
1999 3,299 824.75 159.66
1 In an attachment to the notice of deficiency for
1998, respondent notes: “Since this report does not
reflect your prepayment credits of $1,740.00, you may
not owe the total amount shown on the enclosed report.”
Respondent has also moved the Court to impose a penalty on
petitioner on the grounds that petitioner’s position in this case
is frivolous and has been maintained primarily for delay. The
deficiencies, the additions to tax, and the motion remain in
issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
For 1998, the principal adjustments giving rise to the
deficiency result from respondent’s inclusion in petitioner’s
gross income of $15,873 of capital gain, $6,034 of wages received
from Oxnard Building Materials, $33,850 and $1,900 of nonemployee
compensation received from Holoworld, Inc., and Flannery, Inc.,
respectively, $67 of interest received from Washington Mutual
Bank, FA, $241 of dividends received from assorted payers, and
the addition of self-employment tax of $5,051. For 1999, the
principal adjustments giving rise to the deficiency result from
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Last modified: May 25, 2011