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did not have any Federal income tax withheld and did not make any
estimated tax payments for the 2000 and 2001 taxable years.
On November 28, 2005, respondent issued the aforementioned
notices of deficiency in which, for petitioner’s 2000 taxable
year, respondent determined a Federal income tax deficiency in
the amount of $2,014.20 and additions to tax pursuant to sections
6651(a)(1) and (2) and 6654(a) in the amounts of $453.20,
$503.55, and $107.60, respectively. For petitioner’s 2001
taxable year, respondent determined a Federal income tax
deficiency in the amount of $2,851 and additions to tax pursuant
to sections 6651(a)(1) and (2) and 6654(a) in the amounts of
$641.48, $598.71,4 and $113.94, respectively.
Petitioner then filed timely petitions with this Court. On
February 23, 2007, shortly before trial, petitioner submitted to
respondent’s counsel Forms 1040, U.S. Individual Income Tax
Return, for the 2000 and 2001 taxable years. Those joint returns
included the income of petitioner’s spouse. Respondent agreed
with the filing status and income reported in those returns.
Respondent then filed motions for leave to file amended answers
3(...continued)
for 1999, which is relevant to his liability for an addition to
tax under sec. 6654(a) for the 2000 taxable year.
4 Respondent notes that the addition to tax under sec.
6651(a)(2) was only applied at 0.5 percent for the first 42
months after the return was due and that the addition to tax will
continue to apply, not to exceed 25 percent in the aggregate.
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Last modified: November 10, 2007