Richard Santulli and Virginia Santulli - Page 3

                                        - 3 -                                         
                     Additions  to Tax        Increased Interest                     
                    Sec.           Sec.               Sec.                            
          Year         6659          6661              6621(c)                        
          1980         ---           ---         Due on $81,541.67                    
          1981      $5,765.00        ---         Due on $35,032.19                    
          1982       5,680.80     $56,874.38     Due on $246,443.50                   
          1983         ---        102,750.00     Due on $411,000.00                   

               For 1982 respondent determined an addition to tax under                
          section 6661 of $4,734 as an alternative to the addition to tax             
          under section 6659 shown.                                                   
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               The parties have filed a stipulation of settled issues,                
          which is accepted by the Court.  The issues remaining for                   
          decision are:  (1) Whether petitioners' deductions for losses               
          suffered on certain equipment leasing transactions are allowable,           
          (2) whether the transactions were tax-motivated transactions,               
          rendering petitioners liable for increased interest, and                    
          (3) whether petitioners are liable for certain additions to tax.            
                                  FINDINGS OF FACT                                    
          Introduction                                                                
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact filed by the parties and the                       
          accompanying exhibits are incorporated herein by this reference.            






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