- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011