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Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6662
1999 $212,100 -- -- $42,420
2000 370,017 $45,848 1 36,679
2001 429,787 -- -- 85,957
1 The sec. 6651(a)(2) addition to tax is 0.5 percent of the
unpaid tax liability that will be added to the tax for each
month, or fraction thereof, of nonpayment, up to a maximum of 25
percent, based upon the liability shown on the sec. 6020(b)
return, or the final determined liability, if less.
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.
In the answer, respondent conceded the section 6651(a)(2)
addition to tax. Additionally, respondent alleged that the
correct amounts of deficiencies in, additions to, and penalties
on petitioner’s Federal income tax are as follows:1
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1999 $207,244 -- $41,449
2000 300,102 $44,899 60,020
2001 429,487 69,908 85,897
The issues for decision are: (1) Whether petitioner
substantiated the amounts of his claimed gambling losses for
1999, 2000, and 2001; (2) whether petitioner is liable for
additions to tax pursuant to section 6651(a)(1) for 2000 and
1 Amounts are rounded to the nearest dollar.
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Last modified: March 27, 2008