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OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: Respondent determined
deficiencies in petitioners' Federal income taxes and additions
to tax with respect to the following tax years:
Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659(a) 6661(a)
1980 $ 2,822 $141 -- -- $ 847 --
1983 14,045 -- $702 * 3,092 $ 900
1984 13,485 -- 674 * 2,072 1,491
* 50 percent of the interest due on the deficiency.
Respondent also determined that petitioners were liable for
the increased rate of interest under section 6621(c), for each of
the taxable years at issue.
Prior to trial, respondent filed a motion for leave to file
an amended answer to claim an increased deficiency in tax for the
year 1980. The deficiency for 1980 arises from the carryback of
an investment tax credit by petitioners for the year 1983. On
their 1983 income tax return, petitioners reported an investment
tax credit of $17,924.08 from their investment in a partnership
discussed later in this opinion. Petitioners utilized $15,101.95
of the investment tax credit on their 1983 return and carried
back the unused credit to their 1980 tax year. Petitioners
received a tentative refund of $2,822 for their 1980 tax year,
and that is the amount of deficiency in tax set out in the notice
of deficiency for 1980. Later, respondent's Service Center noted
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