- 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011