- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011