- 2 - In the answer, respondent conceded that the addition to tax under section 6651(a)(2) is not applicable to petitioner’s 2001 and 2002 tax years. As a result, respondent alleged that “Petitioner is liable for the additions to tax attributable to I.R.C. section 6651(a)(1) for the years 2001 and 2002 in the amounts of $1,403.25 and $2,146.00, respectively” (thus misstating the amounts for each year). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are whether respondent’s determinations should be sustained on the existing record and whether petitioner is entitled to any deductions or exemptions not allowed in the statutory notices. FINDINGS OF FACT Petitioner resided in Georgia at the time that he filed his petition. During 2000 and 2001, he performed services as a truck driver for Jimmy Harris Trucking, Inc. In 2002, he also performed services for Vandy Trucking, Inc., and Peters Hauling, Inc. He received compensation for his services. Petitioner maintained a savings account at Farmers and Merchants Bank during 2002 and received interest on that account. During 2002, petitioner received income from Prime America Shareholder Services. During 2002, petitioner and his wife were divorced.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007