- 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
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