- 2 - Respondent also determined that petitioners are liable for increased interest under section 6621(c) for the portion of the underpayment attributable to tax-motivated transactions. After concessions, we must decide the following issues: 1. Whether petitioners may deduct an amount equal to their cash investment in Century Concepts, Inc., in the years in issue. We hold that they may not. 2. Whether petitioners are liable for additions to tax for the years in issue for: (a) Negligence under section 6653(a), and (b) valuation overstatement under section 6659. We hold that they are. 3. Whether petitioners are liable for increased interest on substantial underpayments due to tax-motivated transactions under section 6621(c) for the years in issue. We hold that they are. Petitioners concede that they are not entitled to claim the investment tax credit for their investment in Century Concepts. References to petitioner are to Bevel M. Hoffpauir. Section references are to the Internal Revenue Code in effect for the taxable years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011