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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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Last modified: May 25, 2011