- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011