- 2 - 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.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007