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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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