- 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.
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Last modified: May 25, 2011