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of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
NAMEROFF, Special Trial Judge: Respondent determined
deficiencies, additions to tax, and increased interest as
follows:
Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6651(a)(1) 6661(a) 6621(c)
1980 $ 8,689 1$434.45 --- --- --- 2
1981 11,311 565.55 3 --- --- 2
1983 9,258 462.90 3 --- $2,314.50 2
1984 14,139 960.80 3 $3,534.75 3,534.75 2
1 The Code section for 1980 is 6653(a).
2 Interest on the entire deficiency to be computed at 120 percent of the standard
underpayment rate.
3 50 percent of the interest due on the deficiency.
Initially, in the notice of deficiency, respondent
determined adjustments to petitioners' income by disallowing
their claims to losses with respect to the Winthrop Trust and
their claims to distributive shares of partnership losses of the
Kathmar Company in which petitioners are the two general
partners, each having a 50-percent interest. In a Stipulation of
Settlement filed with the Court on January 9, 1995, the parties
settled all issues pertaining to the Winthrop Trust.
Specifically, the parties agreed that petitioners are allowed
ordinary losses of $8,506 for 1983 and $6,441 for 1984
attributable to the Winthrop Trust. With respect to the
additions to tax and increased interest the parties agreed as
follows:
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