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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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