- 3 -
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1998 $9,294 $1,862.25 -- --
1999 2,298 574.50 -- $111.21
2001 51,948 12,987.00 -- 2,076.02
2002 1,759 395.78 $114.34 --
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioner assigned error to those determinations.
Respondent has conceded that certain amounts included by him in
petitioner’s income for each of the years in issue were
improperly included. He has also conceded (1) the $2,076.02
addition to tax under section 6654(a) for taxable year 2001 and
(2) the $114.34 addition to tax under section 6651(a)(2) for
taxable year 2002. The remaining issues for decision are whether
petitioner (1) underreported his income during one or more of the
years in issue, and (2) is liable for the additions to tax under
section 6651(a)(1) for failure to timely file a return for each
of the years in issue and under section 6654 for failure to pay
estimated income taxes for 1999.
On June 6, 2005, at the conclusion of the trial, respondent
moved to impose a penalty on petitioner under section 6673(a)(1).
We shall rule on that motion at the conclusion of this report.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007