David C. Wilson - Page 4

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          21243-85, additions to tax for 1981 in the amount of $7,364 under           
          section 6659 for valuation overstatement, in the amount of $1,898           
          under section 6653(a)(1) for negligence, and under section                  
          6653(a)(2) in an amount equal to 50 percent of the interest due             
          on the underpayment attributable to negligence; and (2) in the              
          Sorey case, docket No. 7908-89, additions to tax in the amount of           
          $501 and $19 under section 6653(a) for taxable years 1978 and               
          1979, respectively.                                                         
               In her opening brief in docket No. 7908-89, respondent                 
          asserted that Sorey was liable for the addition to tax under                
          section 6659 for 1981 in the amount of $1,442.60, as opposed to             
          $3,521.10 as determined in the notice of deficiency.  We consider           
          the section 6659 addition to tax for 1981 asserted in docket No.            
          7908-89 reduced to correspond to the amount in dispute as set               
          forth in respondent's opening brief and amend the pleadings to              
          conform to the proof pursuant to Rule 41(b).                                
               The issues in these consolidated cases are:  (1) Whether               
          expert reports and testimony offered by respondent are admissible           
          into evidence; (2) whether petitioners are entitled to claimed              
          deductions and tax credits with respect to Clearwater as passed             
          through Efron Investors to petitioners; (3) whether petitioners             
          are liable for additions to tax under section 6653(a)(1) and (2)            
          for 1981 and whether petitioner Sorey is liable for additions to            
          tax for negligence or intentional disregard of rules or                     
          regulations under section 6653(a) for 1978 and 1979; (4) whether            




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