Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE ARMEN, Special Trial Judge: Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax for the taxable years as follows: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659(a) 1980 $10,180 $509 --- --- $3,054 1981 9,620 --- $481 1 2,886 1982 700 --- 35 2 --- 1983 755 --- 38 3 --- 1 50 percent of the interest due on $9,620. 2 50 percent of the interest due on $700. 3 50 percent of the interest due on $755. Respondent also determined that petitioners are liable for the increased rate of interest under section 6621(c) for the taxable years 1980 and 1981. After concessions by the parties,2 the only issue remaining 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Petitioner Estate of Mark R. Woodward, Deceased, concedes all of the determinations set forth in the notice of deficiency except for the additions to tax under sec. 6659(a) for the taxable years 1980 and 1981. For the taxable years 1980 and 1981, petitioner Lillian H. Woodward (petitioner) concedes that if petitioner is not an innocent spouse, then she is liable for the deficiencies in tax and additions to tax under secs. 6653(a), 6653(a)(1), and 6653(a)(2), and the increased rate of interest under sec. 6621(c) as determined by respondent. For the taxable years 1982 and 1983, petitioner concedes that she is liable for the deficiencies in tax and additions to tax as determined by respondent. For the taxable years 1980 and 1981, respondent concedes that petitioners are not liable for the addition to tax under sec. 6659(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011