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tax under section 6651(a)(1), and civil fraud penalties under section 6663(a) as follows:[1]
| Year | Deficiency | Additions to tax Sec. 6651(a)(1) |
Penalties Sec. 6663(a) |
|---|---|---|---|
| 1998 | $111,959 | $28,373 | $83,969 |
| 1999 | 192,763 | 48,191 | 144,572 |
| 2000 | 191,334 | 47,833 | 143,500 |
| 2001 | 153,432 | 38,358 | 115,074 |
| 2002 | 153,300 | 38,325 | 114,975 |
| 2003 | 135,442 | 33,860 | 101,581 |
| 2004 | 265,445 | 66,361 | 199,084 |
| 2005 | 297,353 | 74,338 | 223,015 |
| 2006 | 146,487 | 36,622 | 109,865 |
After concessions,[2] the issues for decision are: (1) whether and to what extent
- ↑ Unless otherwise indicated, section references are to the Internal Revenue Code (Code) in effect for the years at issue, and Rule references are to the Tax Court Rules of Practice and Procedure. Monetary amounts have been rounded to the nearest dollar.
- ↑ In the notice of deficiency respondent made the following adjustments: (1) increased gross receipts on petitioner's Schedules C, Profit or Loss From Business, for the years at issue; (2) determined Schedule C business expenses for the years at issue; (3) increased petitioner's interest income for 2000-04; (4) increased petitioner's self-employment tax for the years at issue; (5) disallowed petitioner's claimed personal exemption deductions for the years at issue; and (6) allowed petitioner a rate reduction credit of $300 for 2001.In her petition, petitioner assigns error only to respondent's determinations that she received interest income in 2000-02 and that she received additional Schedule C income during the years at issue. Ordinarily we deem any issue not raised in the assignments of error in the petition conceded. See Rule 34(b)(4).
