§6551

MEMORANDUM FINDINGS OF FACT AND OPINION NEGA, Judge: By notice ofdeficiency dated November 16, 2017, respondent determined a $65,363 deficiency, a $6,537 section 6551(a)(1) addition to tax, and a $13,073 section 6662(a) accuracy-relatedpenalty with respect to SERVED Sep 03 2020 - 2 - [*2] petitioner's Federal income tax for 2014 (year at issue).¹ After concessions,2 the issues for decision are: (1) whether meal and entertainment expenses and travel expenses are deductible as claimed on petitione

Barred overpayments may not be credited against the tax required to be shown on a tax return for purposes ofthe additions to tax under section 6551(a)(1) and (2).

In his motion petitioner contends that: (1) he was a German resident in 2010; (2) section 877A does not apply; and (3) the section 6662 penalty and the section 6551 - 3 - addition to tax do not apply.

ficiency dated February 11, 2013, respondent determined a deficiency in petitioner's 2009 Federal income tax (including self-employmenttax) plus additions to tax as follows: SERVED JUN 2 2 2015 - 2 - [*2] Additions to Tax Deficiency Sec. 6651(a)(1) Sec. 6551(a)(2) Sec. 6654(a) $44,092 $9,920.70 $6,834.26 $1,055.68 The issues for decision are: (1) whetherpetitioner has unreported income as respondent determined; (2) whether petitioner is liable for the additions to tax under sections 6651(a)(1) a

By notice dated March 10, 2014, respondent determined a deficiency in petitioner's income tax for 2010 of$13,160 as well as a penalty for failure to timely file under section 6651(a)(1) of$1,226.93 and a penalty for failure to - 3 - [*3] timely pay under section 6551(a)(2) of$899.75.¹ See sec.

Respondent also determined penalties for fraud under section 66631 of $78,447.75, $46,.413.75, and $39,297.75 for 1991, 1992, and 1993, respectively, as well as additions to tax for fraudulent failure to file under section 6551(f) of $32,980.25 and $232,617.70 for 1994 and 1995, respectively.

15-02; and Giselle M. Wolfe, docket No. 6916-02. SEftVED AUG 1 9 2004 - 2 - penalties for the tax years 1994, 1995, 1996, and 1997 as follows:2 WFO Corp . docket No. 6913-02 Accuracy-related Penalties Addition to Tax Year Deficiencies Sec. 6662 (a) Sec. 6551(a) (1) 1995 $1,725 $345.00 $431.25 1996 95, 228 19, 045 . 60 0 Terence J. and Giselle M. Wolfe docket No. 6914-02 Addition to Tax Year Deficiency Sec. 6651(a) (1) 1996 $22, 762 $130.25 Terence J·. Wolfe docket No. 6915-02 Additions to Tax Ye

.No. 6915-02; and Giselle M. Wolfe, docket No. 6916-02. SEftVED AUG 1 9 2004 penalties for the tax years 1994, 1995, 1996, and 1997 as follows:2 WFO Corp. docket No. 6913-02 Accuracy-related Penalties Addition to Tax Year Deficiencies Sec. 6662(a) Sec. 6551(a) (1) 1995 " $1,725 $345.00 $431.25 1996 95,228 19,045.60 0 Terence J. and Giselle M. Wolfe docket No. 6914-02 Addition to Tax Year Deficiency Sec. 6651(a) (1) 1996 $22 , 762 $130 . 25 Terence J. Wolfe docket No. 6915-02 Additions to Tax Ye

e Appeals Officer found that the estate as of February 1999 had sufficient cash flow to pay the taxes and/or had the ability to borrow to pay the taxes. During the course of the CDP proceeding you raised the issue of abating the penalties under IRC §6551(a)(2). Your request was referred to the North Texas District of the I.R.S. for administrative consideration. Your request was denied. You appealed the decision and the matter was referred to an Appeals Officer who was not previously involved in