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tax under section 6651(a)(1)1 of $2,037, under section 6651(a)(2)
of $498, and under section 6654 of $245. Petitioner petitioned
for a redetermination of the deficiency and the additions to tax.
After concessions,2 the issues for decision are:
(1) Whether respondent issued a valid notice of deficiency
for petitioner’s 2003 taxable year;
(2) whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failing to file his 2003 Federal
income tax return;
(3) whether petitioner is liable for an addition to tax
under section 6651(a)(2) for failing to pay the amount shown as
tax on a return;
(4) whether petitioner is liable for an addition to tax
under section 6654 for failing to pay estimated taxes; and
(5) whether the Court should impose a penalty under section
6673.
1All section references are to the Internal Revenue Code
(Code) in effect for the year in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure. All
monetary amounts are rounded to the nearest dollar.
2Respondent concedes that petitioner had allowable
deductions and credits as follows: Mortgage interest of $9,032,
real estate taxes of $1,791, and a withholding credit of $452.
Respondent also concedes that petitioner is not liable for
additional tax under sec. 72(t), and he is entitled to married
filing separate status with one exemption. Respondent further
concedes that, after taking the above-listed deductions and
exemptions into account, petitioner’s income tax deficiency for
2003 is reduced to $3,854.
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