- 4 - 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) whetherPage: 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