- 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