Kent J. and Ruth W. Dawson - Page 2

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                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               GOLDBERG, Special Trial Judge: Respondent determined the               
          following additions to petitioners' Federal income taxes:                   

                 Additions to Tax         Additional Interest                         
          Sec.        Sec.         Sec.     Sec.        Sec.                          
          Year 6653(a)   6653(a)(1)   6653(a)(2)   6659       6621(c)                 
          1980  $479         ---         ---     $ 2,877         2                    
          1981   ---      $  833          1        4,996         2                    
          1982   ---         737          1        4,421         2                    
          1983   ---       2,812          1       16,870         2                    

          1  50 percent of the interest payable with respect to the portion of the    
          underpayment attributable to negligence.                                    
          2 120 percent of the interest payable under section 6601 with respect to any
          substantial underpayment attributable to tax-motivated transactions.        
               Following a concession by petitioners,2 the issues for                 
          decision are: (1) Whether petitioners are liable for an addition            
          to tax under section 6653(a) for 1980; (2) whether petitioners              
          are liable for additions to tax under section 6653(a)(1) and (2)            
          for tax years 1981, 1982, and 1983; and (3) whether petitioners             
          are liable for additions to tax under section 6659.                         
               Petitioners were residents of Henderson, Nevada, when the              
          petition was filed in this case. Petitioner Kenneth Dawson                  
          (hereinafter referred to as petitioner) is an attorney engaged in           
          the private practice of law, primarily insurance defense and                


          2    Although respondent determined increased interest under sec.           
          6621(c) for all taxable years at issue, petitioners did not raise           
          this issue in their pleadings or during trial.  As such, the                
          issue is deemed conceded.                                                   





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