- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011