-2-
section 6659 addition to tax, respondent determined a $1,879
addition to tax for substantial understatement of tax pursuant to
section 6661.
Following concessions by petitioners,2 the issues for decision
are: (1) Whether a closing agreement entered into by the parties on
August 7, 1989, precludes petitioners from entitlement to a claimed
depreciation deduction, investment tax credit, and loss from a
program marketed by or on behalf of FoodSource, Inc. (hereinafter,
this program is referred to as the FoodSource program) for 1984;
and if not, (2) whether petitioners are entitled to the
depreciation deduction, investment tax credit, and loss for 1984.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. The record before us is incomplete;
nonetheless, we have attempted, as best we can, to ascertain the
facts necessary to resolve the issues before us.3
1(...continued)
sec. 1511(c)(1), 100 Stat. 2744, former sec. 6621(d) was
redesignated as sec. 6621(c).
Except as otherwise indicated, all section references
are to the Internal Revenue Code for the year under
consideration.
2 Petitioners acknowledge that in the event we sustain
respondent’s deficiency determination, they are liable for both
the sec. 6659 addition to tax and additional interest pursuant to
sec. 6621(c).
3 For a better understanding of the FoodSource program,
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011