- 4 - On April 4, 1995, respondent issued a so-called affected items notice of deficiency to petitioner for each of the taxable years 1984 and 1985. The affected items notices of deficiency set forth respondent's determination that petitioner is liable for additions to tax under sections 6651(a)(1) and 6659 for 1984 and 1985. Respondent determined that petitioner is liable for those additions to tax as a consequence of the adjustments to petitioner's tax liability arising from the disallowance of partnership items of December Associates for 1983, 1984, and 1985. Petitioner invoked this Court's jurisdiction by filing a timely petition for redetermination. The petition includes an allegation that petitioner is entitled to a refund under section 6512 in respect of any taxes assessed or paid after the expiration of the applicable period of limitations. See Barton v. Commissioner, 97 T.C. 548 (1991). After respondent filed her answer, petitioner filed his two motions for partial summary judgment. In his Motion for Partial Summary Judgment Regarding The Overvaluation Penalty, petitioner seeks a ruling that he is not liable for the additions to tax under section 6659 as determined by respondent. Although respondent initially filed an objection to petitioner's motion, respondent subsequently filed a Memorandum of Law, which states as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011