Leon M. and Mary K. Jaroff - Page 6

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          and the Penalty Rate of Interest and To File Supporting                     
          Memorandum of Law under Rule 50.  On that same date, petitioners            
          lodged with the Court a motion for decision seeking relief from             
          the additions to tax for negligence and the increased rate of               
          interest, with attachments, and a memorandum in support of the              
          motion.  Subsequently, respondent filed an objection, with                  
          attachments, and a memorandum in support thereof, and petitioners           
          filed a reply memorandum.  For reasons discussed in more detail             
          at the end of this opinion, and also in Farrell v. Commissioner,            
          T.C. Memo. 1996-295, petitioners' motion shall be denied.  See              
          also Gollin v. Commissioner, T.C. Memo. 1996-454; Grelsamer v.              
          Commissioner, T.C. Memo. 1996-399; Zenkel v. Commissioner, T.C.             
          Memo. 1996-398.                                                             
               The issues remaining in these consolidated cases are:  (1)             
          Whether petitioners are liable for the additions to tax for                 
          negligence under the provisions of section 6653(a); and (2)                 
          whether petitioners are liable for additions to tax under section           
          6659 for underpayments of tax attributable to valuation                     
          overstatements.                                                             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and attached exhibits are incorporated                 
          herein by this reference.                                                   
          A.  The Plastics Recycling Transactions                                     
               These consolidated cases concern petitioners' investments in           




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