§66542

The issues for decision are: (1) whetherpetitioner had unreported income for the taxable years 2000, 2001, 2002, 2003, and 2004 (years at issue); and (2) whether petitioner is liable for additions to tax under section 6651(a)(1) for 2001 and 2003, sections 6651(a)(2) and (f) for 2000, 2002, and 2004, section 66542 for 2000, and for penalties under section 6663 for 2001 and 2003.

Respondent determined deficiencies in income tax and section 6651(a)(1) and section 66542 additions to tax and sent petitioner separate notices of deficiency for each taxable year in issue.