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1982, plus increased interest under section 6621(c).2 In an
amendment to answer, respondent asserted a lesser deficiency for
1982 in the amount of $51,043, plus additions to tax in the
amount of $12,127 under section 6659 for valuation overstatement,
in the amount of $2,552 under section 6653(a)(1) for negligence,
and under section 6653(a)(2) in an amount equal to 50 percent of
the interest due on $50,278. Respondent also asserted that
$50,278 of the deficiency was subject to the increased rate of
interest under section 6621(c).
Petitioners contend that they should be relieved of any
liability for the negligence additions to tax and increased
interest based upon: (1) Respondent's treatment of a purportedly
similarly situated taxpayer in two other cases; (2) a Stipulation
of Settlement agreement executed by petitioners and respondent in
a separate Plastics Recycling case, docket No. 1173-88, which
concerned taxable years 1981 and 1978; and (3) equitable
estoppel.
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
this reference. Vincent and Clotilde Farrell resided in Katonah,
New York, when their petition was filed.
2 Respondent also determined a deficiency in petitioners'
Federal income tax for 1980, and subsequently asserted a lesser
amount in an amendment to answer. On Apr. 22, 1992, respondent
and petitioners filed a Stipulation of Settled Issues resolving
all of the issues relating to taxable year 1980.
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