-2-
Additions to Tax/Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 16663 6654 26651(f)
2000 $13,513 $3,479 $5,076 -- --
2001 22,722 4,876 15,317 -- --
2002 5,644 1,564 3,980 -- --
2003 23,585 -- -- $617 $17,688
1In the alternative to fraud penalties under sec. 6663,
respondent determined accuracy-related penalties under sec. 6662
of $1,354, $4,085, and $1,061 for the years 2000, 2001, and 2002,
respectively.
2In the alternative to a sec. 6651(f) addition to tax for
the year 2003, respondent determined an addition to tax under
sec. 6651(a)(1) in the amount of $5,307.
After concessions,2 the issues for decision are: (1)
Whether petitioner received unreported income for 2000, 2001,
2002, and 2003 (years at issue); (2) whether petitioner is
entitled to certain itemized deductions for the years at issue;
(3) whether petitioner is entitled to a claimed Schedule E,
Supplemental Income and Loss, rental expense deduction for 2001;
(4) whether petitioner is liable for self-employment tax under
section 1401 for 2001, 2002, and 2003; (5) whether petitioner is
liable for fraud penalties under section 6663 for 2000, 2001, and
2002, or alternatively, accuracy-related penalties under section
1(...continued)
otherwise indicated. Amounts are rounded to the nearest dollar.
2In his amendment to answer, respondent conceded income
adjustments related to certain partnership distributions. On
brief, respondent conceded income adjustments related to
Peninsula Communications of $13,376 and $48,001 for tax years
2000 and 2001, respectively. In addition, respondent conceded
adjustments based on bank deposits into California Federal Bank
of $18,527 for tax year 2002.
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Last modified: November 10, 2007