Leo and Pauline Goldman - Page 2

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                         Respondent determined additions to petitioners' Federal                                                              
                income taxes as follows:                                                                                                      
                                                         Additions To Tax                                                                    
                                         Sec.                     Sec.          Sec.                                                          
                         Year            6653(a)(1)                 6653(a)(2)        6661                                                    
                         1983            $1,506                             1      $7,532                                                     
                         1984            81                                 1              --                                                 
                                 1 Amount equal to 50 percent of the interest due on $30,127                                                  
                         and $1,623, which are the portions of the underpayments attributable                                                 
                         to negligence for taxable years 1983 and 1984, respectively.                                                         
                         Respondent also determined that petitioners are liable for                                                           
                increased interest under section 6621(c) on $30,127 for 1983 and                                                              
                on $1,623 for 1984.  (Petitioners did not raise any issue as to                                                               
                section 6621(c), and this Court has no jurisdiction over that                                                                 
                section under the circumstances here presented.  White v.                                                                     
                Commissioner, 95 T.C. 209, 216-217 (1990).)                                                                                   
                         The issues for decision are (1) whether the Court has                                                                
                jurisdiction over this proceeding, and (2) whether the notices of                                                             
                deficiency were issued before the applicable period of                                                                        
                limitations expired.  If we decide these issues unfavorably to                                                                
                petitioners, the parties have agreed to be bound by the                                                                       
                controlling case of Goldman v. Commissioner, T.C. Memo. 1993-480,                                                             
                affd. 39 F.3d 402 (2d Cir. 1994), with regard to the additions to                                                             
                tax.  The controlling case, which is final, sustained                                                                         
                respondent's determinations regarding the additions to tax.                                                                   









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