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).
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