- 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.
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