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Docket No. 4582-93 - Estate of Donald H. Ray, Deceased,
Patricia G. Ray, Independent Executrix,
and Patricia G. Ray:
Additions to tax
Sec. Sec. Sec. Sec. Sec.
Year 6651(a) 6653(a)(1) 6653(a)(2) 6659 6661*
1983 -- $1,489.00 $27,843.54 $8,936.00 $7,447.00
1984 $249.00 3,932.00 1,351.00 539.00 --
* Determined as an alternative to sec. 6659.
Docket No. 4583-93 - Cipriano Dominguez and the Estate of Isabel
Dominguez, Deceased, Cipriano Dominguez,
Independent Executor:
Additions to tax
Sec. Sec. Sec. Sec.
Year 6653(a)(1) 6653(a)(2) 6659 6661*
1983 $782.00 $14,598.09 $4,693.00 $3,911.00
* Determined as an alternative to sec. 6659.
Respondent assessed deficiencies in income taxes
attributable to the settlement of petitioners' partnership items.
Separate notices of deficiency, upon which these cases are based,
were issued for additions to tax. There is no dispute that
petitioners settled the partnership items, and, having done so,
petitioners' share of those items became nonpartnership items.
Sec. 6231(b)(1)(C). The only question is whether the notices of
deficiency for additions to tax were issued prior to the
expiration of the applicable period of limitations for
assessment. We hold that respondent issued notices of deficiency
as to the additions to tax at issue in these cases prior to the
expiration of the period of limitations for assessment.
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