Charles Raymond Wheeler - Page 3

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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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