- 2 - Respondent determined deficiencies of $3,175.85 and $3,554, respectively, in petitioner’s Federal income taxes for the years 2002 and 2003, an addition to tax under section 6651(a)(1) for the year 2002 in the amount of $511.71, an additional tax under section 72(t) in the amount of $107.85 for the year 2002, a liability of $2,505 for self-employment tax under section 1401(a) for the year 2003, and a negligence penalty under section 6662(a) for both years. In a trial memorandum, respondent notes that, prior to trial, respondent conceded a capital gain loss of $9,405 for the year 2002 that had been disallowed in the notice of deficiency, and, therefore, petitioner is entitled to a capital loss deduction of $3,000 for 2002 and a carryover capital loss deduction of $3,000 to 2003. As a result of this concession, the deficiencies, the addition to tax, and the penalties were reduced to the following amounts: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662 2002 $1,316 $100 $263 2003 3,138 -- 628 Subsequent to these concessions, respondent filed an answer alleging that petitioner is liable for the fraud penalty underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011