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Respondent determined a deficiency of $22,285 in
petitioner’s 1998 Federal income tax, a section 6651(a)(1)
addition to tax of $10,585.38, and a section 6654(a) addition to
tax of $1,011.45. In his answer, respondent adjusted the amount
of the section 6651(a)(1) addition to tax to $5,571.25.2
The issues for decision are: (1) Whether petitioner is
liable for the deficiency determined by respondent; (2) whether
petitioner is liable for the failure to file addition to tax
under section 6651(a)(1); (3) whether petitioner is liable for
the failure to pay estimated tax addition to tax under section
6654(a); and (4) whether petitioner is liable for the penalty
pursuant to section 6673.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Santa Clara, California.
2 Respondent attached a Form 4549, Income Tax Examination
Changes, to the notice of deficiency. In the Form 4549,
respondent asserted a sec. 6651(a)(1) addition to tax of
$5,014.13 and a sec. 6651(a)(2) addition to tax of $5,571.25.
These additions to tax were consolidated on the first page of the
notice of deficiency where respondent asserted a sec. 6651(a)(1)
addition to tax in the amount of $10,585.38. In his answer,
respondent concedes the sec. 6651(a)(2) addition to tax asserted
in Form 4549, and as a result, increased the sec. 6651(a)(1)
addition to tax initially asserted in Form 4549 to the maximum
amount of 25 percent of the amount required to be shown as tax on
the return.
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Last modified: May 25, 2011