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Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c)
1978 $39,133 $1,956.65 -- -- -- *
1979 34,365 1,718.25 -- -- -- *
1980 94,226 4,711.30 -- -- -- *
1981 34,181 -- $1,709.05 ** $1,910.70 *
* Amount equal to 120 percent of the interest payable under
sec. 6601 with respect to any substantial underpayment attributable
to tax-motivated transactions.
** Amount equal to 50 percent of the interest due on $34,181
on the portion of the underpayment attributable to negligence.
This case was submitted fully stipulated as to the
Securities Arbitrage Company issue. The stipulated facts are so
found. For clarity and convenience, the facts and opinion have
been combined.
The Court must decide whether a Closing Agreement executed
by the parties entitles petitioners to exclude from income
guaranteed payments received by petitioner husband from
Securities Arbitrage Company in 1980 and 1981. (An issue with
respect to Federal Arbitrage Company, another partnership,
remains for resolution before a decision can be entered in this
case.)
Petitioners resided in West Nyack, New York, when their
petition was filed.
During the years in issue, Hugh Janow (petitioner) was a
general partner in a limited partnership, Securities Arbitrage
Company (Securities). Securities is one of several partnerships
that comprise respondent's Cralin Commodity National Tax
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