Bernhard F. and Cynthia G. Manko - Page 4

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          III. The Case Herein (Manko II)                                             
               Respondent determined deficiencies in petitioners' Federal             
          income taxes, additions to tax, and additional interest as follows:         

                         Additions to Tax and Additional Interest                     
          Sec.       Sec.          Sec.         Sec.        Sec.       Sec.     Sec.  
          Year   Deficiency   6653(a)   6653(a)(1)   6653(a)(2)   6653(b)(1)   6653(b)(2)   6661    6621(c)
          1979   $2,676,752   $133,838     ---          ---           ---         ---       ---       2
          1980    1,926,696     96,335     ---          ---           ---         ---       ---       2
          1981    2,284,248      ---    $114,212         1             ---         ---       ---       2
          1982    1,794,143      ---      89,707         1         $897,072         1      $448,536    2
          1983    1,649,568      ---      82,478         1          824,784         1       412,392    2
          1    50 percent of the interest due on the deficiency.                      
          2    120 percent of the interest due on the entire deficiency.  Pursuant to the
          Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(c)(1), 100 Stat. 2744, former
          sec. 6621(d) was redesignated as sec. 6621(c).                              
          For 1982 and 1983, the negligence additions to tax were imposed             
          with respect to the liability of Cynthia G. Manko, and the fraud            
          additions to tax were imposed with respect to the liability of              
          petitioner.1                                                                
               All section references are to the Internal Revenue Code in             
          effect for the years under consideration, unless otherwise                  
          indicated.  All Rule references are to the Tax Court Rules of               
          Practice and Procedure.                                                     
               The primary issue for decision is whether the settlement               
          agreement applicable to petitioner's Arbitrage Management gains and         
          losses in 1978 (Manko I) is likewise applicable to his Arbitrage            
          Management gains and losses for the years in issue, 1979 through            

               1    The notice of deficiency also made adjustments for                
          items unrelated to petitioner's interest in the partnerships,               
          including an adjustment for unreported interest income for 1980.            
          These unrelated issues have not been resolved.                              




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