- 2 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011