- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008