David A. Sullivan v. Commissioner of Internal Revenue

GEORGE C. PRATT, Circuit Judge:

Petitioner David A. Sullivan appeals from a decision of the United States Tax Court, Joel Gerber, Judge, that charged him with an income tax deficiency of $26,-547 for 1983, plus additions to tax under 26 U.S.C. §§ 6651 (failure to file tax return), 6653(a)(1) & (2) (negligent underpayment of tax), and 6661 (substantial underpayment of tax) (1982). The commissioner agrees that the tax court erred in imposing additions to tax under §§ 6651, 6653(a)(2) and 6661; consequently, those determinations are vacated, and this opinion is concerned only with whether…