Bevel M. and Patricia N. Hoffpauir - Page 2

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               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.                                            










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