- 2 - and 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 DEAN, Special Trial Judge: Respondent determined deficiencies in, additions to, and increased interest on petitioners' Federal income tax as follows: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency1 6653(a)(1) 6653(a)(2) 6659 26661 1978 $30,342 $1,517.10 -- $8,315.40 $7,585.50 1979 20,794 1,039.70 -- 6,210.00 5,198.50 1981 25,168 1,258.40 50 percent of 7,550.40 6,292.00 interest due on $25,168 1982 15,720 786.00 50 percent of 2,607.90 3,930.00 interest due on 3$8,693 1 Sec. 6621(c) interest is determined to apply to the entire deficiency as determined for each of the taxable years 1978, 1979, 1981, and 1982. 2 Sec. 6661 is asserted as an alternative to sec. 6659. In the alternative, the addition is asserted as 25 percent of the underpayments of $30,342, $20,794, $25,168, and $15,720 for the taxable years 1978, 1979, 1981, and 1982, respectively. 3 This amount is taken from the partial copy of the notice of deficiency attached to the petition. We note that this amount differs from the amount listed in respondent's Trial Memorandum filed February 2, 1995. Petitioners conceded on opening statement that they do not dispute the accuracy of the deficiencies and additions to tax and the interest on tax motivated transactions contained in the statutory notice of deficiency, as modified by respondent's trial 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011