Jesus V. Cutillar and Nora Cutillar - Page 2

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               During the 1982 taxable year, petitioner Jesus V. Cutillar             
          was a partner in the partnership of Waltbar & Associates                    
          (Waltbar).  Waltbar invested in two other partnerships, Whitman             
          Recycling Associates (Whitman) and Stevens Recycling Associates             
          (Stevens).  Waltbar was a pass-thru partner in Whitman and                  
          Stevens.  In January and February 1995, following adjustments at            
          the partnership level to Whitman and Stevens for the 1982 taxable           
          year, respondent notified petitioners that their distributive               
          share of income/loss/credit from Waltbar for 1982 had been                  
          adjusted to reflect respondent’s adjustments to Whitman and                 
          Stevens.  These adjustments were the result of partnership level            
          proceedings conducted pursuant to sections 6221-6233 and resulted           
          in tax assessments against petitioners.                                     
               On March 16, 1995, respondent issued a notice of deficiency            
          (the first notice of deficiency) to petitioners at their last               
          known address, 4005 Forsythe Way, Tallahassee, Florida, 32308-              
          2360, determining the following additions to tax with respect to            
          the tax adjustments related to Stevens:                                     

                    Additions to Tax                                                  
          Year         Sec. 6653(a)(1)    Sec. 6653(a)(2)                             
          1982            $15.60          50 percent of the                           
          interest due on                                                             
          $312                                                                        


               1(...continued)                                                        
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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