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Docket No. 37669-85
Additions to Tax
Year1 Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6651
1979 $12,476 2$624 -- --
1980 19,023 2 951 -- --
1981 13,573 679 3 $4,072
Docket No. 38099-85
Additions to Tax
Year1 Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6651
1982 $28,019 $1,705 3 $3,167
1Increased interest under sec. 6621(c) was imposed.
2The additions to tax for 1979 and 1980 were determined
pursuant to sec. 6653(a).
350 percent of the interest due on $13,573 and $28,019 for
taxable years 1981 and 1982, respectively.
After concessions, the issues for decision are:2
(1) Whether a lease transaction entered into by Energy
Resources, Ltd. (ERL), a limited partnership of which petitioner
husband was a limited partner, was devoid of economic substance.
We hold that it was.
2The petition also presents an issue of whether respondent
is barred from assessing the taxes at issue pursuant to sec.
6501. Petitioners, however, did not address this issue at trial,
nor did they discuss it in their posttrial briefs. Accordingly,
the issue is deemed to have been conceded and is not discussed
herein.
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