Albert R. and Phyllis F. Dworkin - Page 4

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            is not includable in petitioners' taxable income for tax year                                  
            1981.  Lastly, the parties stipulated that sections 6653, 6661,                                
            and 6621(c) were not applicable to any of the adjustments set                                  
            forth in the Partial Stipulation of Settlement.                                                
                  After trial, respondent conceded a reduction in the section                              
            6659 addition to tax for 1981.  In the notice of deficiency,                                   
            respondent determined a section 6659 addition to tax in the                                    
            amount of $21,295.  In her reply brief, respondent asserted that                               
            the section 6659 addition to petitioners' tax for 1981 should be                               
            reduced to $19,083.  We consider that respondent has conceded the                              
            addition to tax under section 6659 for 1981 in excess of the                                   
            amount of such addition to tax in dispute as set forth in                                      
            respondent's reply brief.                                                                      
                  The issues for decision with respect to petitioners' Federal                             
            income tax for 1981 are:  (1) Whether petitioners are liable for                               
            additions to tax for negligence or intentional disregard of rules                              
            or regulations under section 6653(a)(1) and (2); and (2) whether                               
            petitioners are liable for the addition to tax under section 6659                              
            for an underpayment of tax attributable to valuation                                           
                                           FINDINGS OF FACT                                                
                  Some of the facts have been stipulated and are so found.                                 
            The stipulated facts and attached exhibits are incorporated by                                 
            this reference.  Petitioners resided in Longboat Key, Florida,                                 
            when their petition was filed.                                                                 

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