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Respondent filed a motion for partial summary judgment in
which she asserts that petitioner is not entitled to use income
averaging for the taxable years 1980 and 1981. Petitioner filed
an objection to respondent's motion and also filed a cross-motion
for partial summary judgment. Petitioner argues that he is
entitled to income averaging for the taxable years 1980 and 1981.
Respondent filed a notice of objection to petitioner's cross-
motion for partial summary judgment.
Respondent issued a notice of deficiency on April 5, 1990,
determining deficiencies in and additions to petitioner's Federal
income taxes for the taxable years 1980 through 1982 as follows:
Additions to Tax
Year Deficiency Sec. 6653(a) Sec. 6653(a)(1) Sec. 6661
1980 $76,748.00 $3,837 --- ---
1981 125,013.15 --- $6,250.65 ---
1982 47,634.00 --- 2,381.70 $11,908.50
The notice of deficiency determined a number of adjustments
related to Merit Securities issues. See Seykota v. Commissioner,
T.C. Memo. 1991-234, supplemented by T.C. Memo. 1991-541. A
timely petition was filed invoking the jurisdiction of this
Court. Soon after the pleadings were closed, the parties filed a
stipulation of settlement of tax shelter adjustments wherein they
agreed to be bound by the test case litigation in Seykota v.
Commissioner, supra.
1(...continued)
Procedure.
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