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Additions to Tax
Sec. Sec.
Sec. 6653(a)(1)/ 6653(a)(2)/ Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a)
1985 $352,825 $88,206 $17,641 * $ 88,206
1986 85,404 21,351 4,270 * 21,351
1987 526,354 __ 26,318 * 131,589
* 50 percent of interest due on portion of
underpayment attributable to negligence.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concession of some issues by each party, the primary
issues remaining for decision are: (1) The amount, if any, of
net operating loss, investment interest, and investment credit
carryovers from 1984 to which petitioners are entitled for the
years in dispute; (2) whether a residence sold by petitioners in
1986 was used by petitioners as a personal residence; (3) the
amount of gain petitioners realized in 1985, 1986, and 1987 in
connection with two transactions relating to the sale of stock;
(4) whether petitioners have substantiated claimed operating
expenses and costs-of-goods sold with regard to various
businesses; (5) whether Eva Leavell has substantiated for 1986 a
claimed net operating loss of $20,378 relating to oil production;
and (6) whether petitioners are liable for the additions to tax.
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Last modified: May 25, 2011