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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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Last modified: May 25, 2011