- 4 -
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
overstatement.
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011