Bagby v. Commissioner

Beghe, Judge:

Respondent determined the following deficiencies in and additions to petitioner’s Federal income tax:

Additions to tax

Year Deficiency Sec. 6651(a) Sec. 6653(a) Sec. 6654(a)

1985 $17,085 $2,375 1$854 4^ co

1986 23,748 4,353 Oi

1987 22,830 2,145 11,142 to

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 three separate statutory notices, respondent determined that petitioner failed to file tax returns for the years in issue and determined deficiencies and additions to…