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the returns after their due dates. He filed the 1990 return on
November 7, 1992, the 1991 return on August 26, 1996, the 1992
return on October 29, 1994, and the 1993 return on January 26,
1998.
On the 1990 return, the Scotts reported Mr. Scott’s wages of
$29,223, petitioner’s wages of $8,382, a $10,867 net operating
loss from Karnival Klassics, and a $141 overpayment of tax. On
February 23, 1994, respondent sent to the Scotts a notice of
deficiency for 1990 determining a $4,193 deficiency in income
tax, an addition to tax under section 6651, and a penalty under
section 6662(a). The Scotts petitioned this Court for
redetermination of the deficiency, the addition to tax, and the
penalty. On March 14, 1995, the Court entered a stipulated
decision that the Scotts were liable for a $3,176 deficiency in
income tax attributable to the disallowance of the $16,360 of
expenses claimed for the Karnival Klassics activity, an addition
to tax of $795 under section 6651(a), and a penalty of $635 under
section 6662(a).
On the 1991 return, the Scotts reported Mr. Scott’s wages of
$26,232, petitioner’s wages of $8,941, $879 of income from
petitioner’s janitorial services business, $2,796 from Mr.
Scott’s bookkeeping business, and an $8 loss from Karnival
Klassics. The 1991 return showed total tax of $3,917, withheld
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