-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007