- 3 - 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:Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011