James Edward Taylor - Page 3




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          by any other court, and this opinion shall not be treated as                
          precedent for any other case.                                               
               In a notice of deficiency, respondent determined a                     
          deficiency of $33,456 in petitioner’s Federal income tax for the            
          year 2003; an addition to tax under section 6651(a)(1) in the               
          amount of $6,211; an addition to tax under section 6651(a)(2) in            
          the amount of $2,208.48; and an addition to tax under section               
          6654.  At trial, respondent conceded to a reduction of the                  
          deficiency from $33,456 to $31,367 and conceded the section                 
          6651(a)(2) addition to tax.2  Additionally, the parties reached a           
          basis of settlement on unreported wage and salary income paid to            
          petitioner during the year at issue, as well as income realized             
          by petitioner from real estate sales during that year.3                     
          Subsequent to trial, respondent conceded the addition to tax                
          under section 6654.                                                         


               2The deficiency is based upon respondent’s determination               
          that petitioner realized net income from a trade or business                
          activity.  In the notice of deficiency, petitioner’s gross                  
          receipts from that activity were determined to be $91,000.  At              
          trial, respondent conceded to a reduction of the gross receipts             
          to $83,720, resulting in a reduction of the deficiency to                   
          $31,367, as well as a reduction in the secs. 6651(a)(1) and 6654            
          additions to tax.  At trial, respondent further conceded the sec.           
          6651(a)(2) addition to tax, which also necessitates a                       
          recomputation of the sec. 6651(a)(1) addition to tax.  The                  
          decision, therefore, will be entered under Rule 155.                        
               3The parties agreed that petitioner earned wages of $54,869            
          during the year at issue from Lawyers Title Insurance Corp. on              
          which there were income tax withholdings of $5,850.  The parties            
          further agreed that petitioner earned no income from real estate            
          sales during the year at issue.                                             





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