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Peter L. Ente, for petitioners.
Marcie B. Harrison, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined a deficiency in
petitioners' 1982 Federal income tax in the amount of $7,686, and
additions to tax and increased interest as follows:
Sec. 6653(a)(1)1 Sec. 6653(a)(2) Sec. 6661 Sec. 6621
$384.30 50% of the interest $768.60 120% of the
due on $7,686 adjusted rate
This matter is before us on the Commissioner's Motion for Summary
Judgment and/or Entry of Decision and Petitioners' Motion for
Leave to File Amendment to Petition.
Petitioners, Mayer and Ninette Stiskin, are husband and
wife. They resided in New York, New York, at the time their
petition in this case was filed. Use of the word petitioner in
the singular will refer to petitioner husband. In 1980,
petitioner became a limited partner in Opal Leasing Associates
("Opal Leasing" or "the partnership"), a limited partnership.
His interest in Opal Leasing continued at least into 1982.
On June 13, 1986, the Commissioner issued a notice of the
foregoing deficiency to petitioners for the taxable year 1982.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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