- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011