Hector Prowse - Page 3

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               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 under              









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