- 2 - amount of $5,096.25; (2) for failure to pay tax under section 6651(a)(2) in the amount of $1,812; and (3) for failure to pay estimated tax under section 6654(a) in the amount of $786.40. Less than a month before trial, petitioner submitted an income tax return for 2001 to respondent in which he reported more income than respondent had determined and deducted expenses that flowed through to his return from two S corporations. Respondent asserted in an amendment to answer filed 5 days before trial that petitioner’s deficiency for 2001 is $168,424 and that he is liable for additions to tax of $42,106 under section 6651(a)(1) and $2,317 under section 6654(a). After concessions,2 the issues for decision are: 1. Whether petitioner may deduct a greater amount of expenses flowing through to him from his S corporations than respondent allowed. We hold that he may not. 2. Whether petitioner is liable for the addition to tax for failure to timely file his 2001 return under section 6651(a)(1). We hold that he is. FINDINGS OF FACT Some of the facts have been stipulated and are so found. 2 Among other concessions, petitioner concedes he is liable for the addition to tax for failure to pay estimated tax under sec. 6654(a), and respondent concedes that petitioner is not liable for the addition to tax under sec. 6651(a)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011