Richard L. Clark - Page 2




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          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.              







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