Chester H. and Michelle R. Rossman - Page 2

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          tax pursuant to section 6651(f)1 (or, alternatively, section                
          6651(a)(1)) and section 6651(a)(2) with respect to petitioners’             
          Federal income taxes for 1997 through 2000.  By stipulation, the            
          parties agreed to the following reduced tax deficiencies:                   
                              Year           Deficiency                               
                              1997           $14,062                                  
                              1998           24,266                                   
                              1999           87,662                                   
                              2000           56,572                                   
               After further concessions,2 the remaining issue for decision           
          is whether petitioner is liable for additions to tax under                  
          section 6651(f) for the 1997, 1998, 1999, and 2000 taxable years.           







               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code (Code) in effect for the years in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               2 By stipulation, the parties agreed that petitioner                   
          Michelle R. Rossman (Ms. Rossman) is not liable for any of the              
          income tax deficiencies or additions to tax.  Thus, all future              
          references to “petitioner” will be to Chester H. Rossman II.                
               At trial, respondent agreed that the only remaining issue              
          was whether petitioner was liable for an addition to tax under              
          sec. 6651(f) or, in the alternative, sec. 6651(a)(1) for 1997               
          through 2000.  In his pretrial memorandum, petitioner conceded              
          the applicability of sec. 6651(a)(1) to the stipulated                      
          deficiencies if sec. 6651(f) does not apply.  The parties                   
          stipulated that petitioner is not liable for any additions to tax           
          under sec. 6651(a)(2) for 1997 through 2000.                                





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