United States Tax Court September 27, 1990, Docket No. 322-89 (Wood v. Commissioner)

lead-opinion

COHEN, Judge:

Respondent determined that petitioner is liable for excise taxes under section 4975(a) in the amount of $3,000 for 1984, $5,700 for 1985, and $5,700 for 1986. Respondent also determined that petitioner is liable for additions to tax under section 6651(a)(1) for failure to file excise tax returns, but respondent has now conceded the additions to tax.