Robert W. and Vivian Toan - Page 5




                                        - 5 -                                         

               On May 31, 1995, respondent issued separate notices of                 
          deficiency to petitioners for their 1979, 1980, and 1981 taxable            
          years (separately referred to as the 1979 notice, 1980 notice,              
          and 1981 notice, respectively).  These notices underlie the                 
          additions to tax at issue.  The 1979 notice reflects respondent’s           
          determination that the portion of the disallowed investment tax             
          credit that petitioners carried back to 1979 results in an                  
          underpayment of tax of $71 for 1979.  The 1979 notice determined            
          that petitioners were liable for a $21 addition to tax under                
          section 6659 as a result of this underpayment.  The 1980 notice             
          reflects respondent’s determination that the portion of the                 
          disallowed investment tax credit that petitioners carried back to           
          1980 results in an underpayment in tax of $10,331 for 1980.  The            
          1980 notice determined that petitioners were liable for a $3,099            
          addition to tax under section 6659 as a result of this                      
          underpayment.  The 1981 notice reflects respondent’s                        
          determination that the portion of the disallowed investment tax             
          credit that petitioners carried back to 1981 results in an                  
          underpayment in tax of $1,926 for 1981.  The 1981 notice                    
          determined that petitioners were liable for a $578 addition to              
          tax under section 6659 as a result of this underpayment.                    
               Approximately 11 years before respondent issued these                  
          notices of deficiency to petitioners, respondent issued a notice            
          of deficiency (the 1984 notice) to petitioners for 1980                     





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