Estate of Ronald Busch, Deceased, Rochelle Busch, Executrix and Rochelle Busch, et al. - Page 4

                                        - 4 -                                         
                  Additions to Tax                                                    
     Docket Nos.    Petitioners    Year   Sec. 6653(a)(1)   Sec. 6653(a)(2)   Sec. 6659
     599-89        Busch         1982        $2,621            1            $15,726   
     1643-89        Snyder        1981         5,123            1             30,738  
     618-90        Snyder        1982         5,915            1             31,453   
     1    50 percent of the interest payable with respect to the portion of the underpayment
     attributable to negligence.                                                      
          In addition, respondent determined in each notice of deficiency             
          that interest on deficiencies accruing after December 31, 1984,             
          would be calculated at 120 percent of the statutory rate under              
          section 6621(c).                                                            
               With respect to petitioner Snyder, in her posttrial brief              
          respondent asserted a lesser deficiency2 for 1982 and lesser                
          additions to tax for 1981 and 1982.  She reduced the 1982                   
          deficiency to $109,133; the addition to tax under section                   
          6653(a)(1) for 1982 to $5,242; and the addition to tax under                
          section 6659 for both 1981 and 1982 to $24,783 and $25,114,                 
          respectively.  In addition, respondent conceded that Snyder is              
          not liable for the section 6661 addition to tax for taxable year            
          1982.  She also noted that the addition to tax under section 6659           
          for the years 1981 and 1982 is to be applied only to the portions           
          of the deficiencies attributable to the disallowed credits from             

          2    Part of the deficiency determined for 1982 was due to                  
          respondent's disallowance of a portion of alimony payments and              
          $20,147 in farming activity losses claimed by Snyder.  The                  
          parties filed a Stipulation of Settled Issues with respect to               
          these items on March 28, 1994.  Respondent conceded the alimony             
          deduction in full and $11,566 of the farming activity losses,               
          while Snyder conceded $8,581 of the farming activity losses.                
          Respondent also conceded that no portion of any underpayment                
          resulting from the $8,581 of disallowed farming activity losses             
          is subject to the additions to tax under secs. 6653(a) and 6659.            




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