David and Ira Kaye Kessel - Page 3




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          subsequent section references are to the Internal Revenue Code in           
          effect for the year in issue.                                               
               Respondent determined that petitioners were liable for the             
          following additions to tax for taxable year 1982:  $523 under               
          section 6653(a)(1); 50 percent of the interest due on an                    
          underpayment of $10,460 under section 6653(a)(2); and $2,615                
          under section 6661.  The issues for decision are:  (1) Whether              
          petitioners are liable for additions to tax for negligence under            
          section 6653(a); and (2) whether petitioners are liable for the             
          addition to tax for a substantial understatement under section              
          6661.  The issues in this case concern the participation of                 
          petitioners as limited partners in the Utah Jojoba I Research               
          limited partnership (Utah I).                                               
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioners resided in Arvada, Colorado, at the time             
          they filed their petition.                                                  
               In 1982, David Kessel (petitioner) was a pediatrician, and             
          Ira Kaye Kessel (Mrs. Kessel) was a registered nurse.  In 1979 or           
          1980, petitioner was referred by another physician to Elroy Jones           
          (Mr. Jones) for his financial planning needs.  Petitioners                  
          believed that Mr. Jones was an independent certified financial              
          planner.  During the times they made their investments,                     
          petitioners did not know that Mr. Jones worked for Coordinated              







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