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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.
In these consolidated cases, petitioner requests
redetermination of deficiencies in the amounts of $24,548 and
$17,985 determined by respondent for taxable years 2002 and 2003,
respectively. Respondent has conceded that petitioner received
compensation as an employee during the taxable years in issue and
that he is not liable for self-employment tax. Petitioner has
conceded that he is liable for income tax. The issues remaining
for decision are: (1) Whether petitioner is entitled to the
benefit of joint filing status and deductions for his wife and
children for 2002 and 2003; (2) whether petitioner is liable for
additions to tax for failure to file returns pursuant to section
6651(a)(1) for 2002 and 2003; and (3) whether petitioner is
liable for additions to tax for failure to pay estimated tax
pursuant to section 6654 for 2002 and 2003.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and related exhibits are incorporated
herein by this reference.
At the time he filed the petitions, petitioner resided in
Ridgewood, New York.
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