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petitioner during 2000 and 2001 and that petitioner was liable
for Federal Insurance Contributions Act (FICA) taxes, income tax
withholding, and Federal Unemployment Tax Act (FUTA) taxes, the
section 6662 accuracy-related penalty, and the addition to tax
under section 6651(a)(1) in the following amounts:
Taxable period ended 2000
Tax/addition/penalty Mar. 31 June 30 Sept. 30 Dec. 31 Total
FICA $6,200.18 $6,200.18 $6,200.18 $6,200.18 $24,800.72
Income tax 11,346.72 11,346.72 11,346.72 11,346.72 45,386.88
Sec. 6651(a)(1) 4,386.73 4,386.73 4,386.73 4,386.73 17,546.92
Sec. 6662 3,509.38 3,509.38 3,509.38 3,509.38 14,037.52
FUTA --- --- --- 3,337.83 3,337.83
Sec. 6651(a)(1) --- --- --- 834.46 834.46
Sec. 6662 --- --- --- 667.57 667.57
Total 25,443.01 25,443.01 25,443.01 30,282.87 106,611.90
Taxable period ended 2001
Tax/addition/penalty Mar. 31 June 30 Sept. 30 Dec. 31 Total
FICA $6,200.17 $6,200.17 $6,200.17 $6,200.17 $24,800.68
Income tax 11,346.72 11,346.72 11,346.72 11,346.72 45,386.88
Sec. 6651(a)(1) 4,386.73 4,386.73 4,386.73 4,386.73 17,546.92
Sec. 6662 3,509.38 3,509.38 3,509.38 3,509.38 14,037.52
FUTA --- --- --- 3,337.83 3,337.83
Sec. 6651(a)(1) --- --- --- 834.46 834.46
Sec. 6662 --- --- --- 667.57 667.57
Total 25,443.00 25,443.00 25,443.00 30,282.86 106,611.86
In his pretrial memorandum, respondent conceded that he has
mistakenly applied both the section 6651(a)(1) addition to tax
and the section 6662 accuracy-related penalty to the periods
ended September 30 and December 31, 2000, and March 31, June 30,
September 30, and December 31, 2001, and provided the following
revised numbers:
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Last modified: November 10, 2007