- 2 -
Additions to Tax
Sec. Sec. Sec.
Year1 Deficiency 6653(a)(1) 6653(a)(2) 6659
1980 $4,898.17 $244.91 2 $1,469.45
1981 5,791.00 289.55 2 1,737.30
1982 934.83 46.74 2 --
1983 6,108.00 305.40 2 1,832.40
1 Increased interest under sec. 6621(c) was imposed.
2 50 percent of the interest payable with respect to the2
portion of the underpayment attributable to negligence.
After concessions, the issues for decision are:
(1) Whether petitioner is entitled to claimed deductions
and a claimed investment tax credit for taxable year 1983 in
connection with his participation in the Century Concepts, Inc.,
Master Video Game Leasing Program. We hold that he is not.
(2) Whether petitioner is liable for the negligence
additions to tax under section 6653(a)(1) and (2) for the taxable
years at issue. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein. Petitioner resided in Corpus Christi,
Texas, at the time the petition was filed in the instant case.
In 1983, petitioner participated in the Century Concepts,
Inc. Master Video Game Leasing Program. In 1983, Century
Concepts, Inc. (Century Concepts or Century), was ostensibly in
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