- 2 - section 6651(a)(1)1 of $6,208,944, and an addition to tax for failure to pay estimated tax under section 6654 of $922,946 for petitioner's 2002 taxable year. In that notice, respondent also determined that petitioner is liable for the addition to tax under section 6651(a)(2) for failure to pay timely in an amount to be calculated at a later date.2 Background On May 1, 2006, petitioner commenced the present case by filing a timely petition contesting respondent's determinations set forth in the notice of deficiency. The petition alleges that respondent erred in computing petitioner's taxable gain from certain stock sales during 2002 by failing to subtract petitioner's bases in those stocks from the sale proceeds. The petition also alleges that petitioner filed a joint 2002 Federal income tax return with her husband, Gary L. Francione, although respondent has no record of receiving any return from petitioner for 2002. Petitioner resided in Newton Square, Pennsylvania at the time the petition was filed. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Respondent has since conceded (by amended answer, discussed infra) petitioner's liability for the addition to tax under sec. 6651(a)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007