Hugh and Linda Janow - Page 2

                                                 - 2 -                                                    
                 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                                      





Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011