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Additions to Tax and Increased Interest
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 Sec. 6621(c)
1981 $5,207 $260.35 1 $1,529.40 2
1982 4,148 207.40 1 948.60 2
1 50% of the interest due on the deficiency.
2 120% of the interest payable under sec. 6601.
By notice of deficiency dated June 10, 1987, respondent
determined deficiencies in, additions to, and increased interest
on petitioners John and Susan Ross' Federal income tax as
follows:
Additions to Tax and Increased Interest
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 Sec. 6621(c)
1981 $6,362 $318.10 1 $1,908.60 2
1982 4,035 201.75 1 1,210.50 2
1 50% of the interest due on the deficiency.
2 120% of the interest payable under sec. 6601.
In the stipulation, petitioners agreed to be bound by the
test case entitled Pinto v. Commissioner, docket No. 17407-86.
This Court entered a decision in the Pinto case on January 18,
1995. The stipulation provides:
With respect to all adjustments in respondent's
notice of deficiency relating to the Scheer Project tax
shelter, more specifically, the limited partnership
entitled Richard II, Ltd., the parties stipulate to the
following terms of settlement:
1. THE ABOVE ADJUSTMENTS ARE THE ONLY ISSUES IN
THIS CASE WITH RESPECT TO ALL PARTIES;
2. The above adjustments, as specified in the
preamble, shall be redetermined by application of the
same formula as that which resolved the same tax
shelter adjustments with respect to the following
taxpayers:
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Last modified: May 25, 2011