- 2 - years 1980 and 1981, respondent determined deficiencies in Hans Hammann's Federal income taxes and additions to tax as follows: Additions To Tax Year Deficiency Sec. 6653(a) Sec. 6653(a)(1) Sec.6653(a)(2) 1980 $2,987 $149.35 --- --- 1981 608 --- $30.40 1 1 This amount is 50 percent of the interest due on any part of the deficiency due to negligence. Respondent also determined deficiencies in petitioners' 1983, 1984, and 1985 Federal income taxes and additions to tax as follows: Additions To Tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661 1983 $10,150 $508 1 $2,538 1984 11,739 587 1 2,935 1985 14,307 715 1 3,577 1 This amount is 50 percent of the interest due on any part of the deficiency due to negligence. Respondent further determined that the increased rate of interest imposed by section 6621(c) was applicable for each year in issue. The issues for decision are: (1) Whether for the years 1983, 1984, and 1985 Hans Hammann conducted a charter boat service with the requisite profit motive to allow for deductions under section 162(a), and, if so, whether petitioners can substantiate the deductions claimed in connection with the charter boat service for the years 1984 and 1985; (2) whether the charter boat service gave rise to investment tax credits for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011