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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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