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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2)
1980 $4,176 $209 --- ---
1981 5,373 --- $269 1
1982 5,335 --- 267 1
1983 2,573 --- 129 1
Additions to Tax Increased Interest
Sec. Sec. Sec.
Year 6659 6661 6621(c)
1980 $1,253 --- 2
1981 1,612 --- 2
1982 1,601 3$1,333.75 2
1983 --- --- 2
1 50 percent of the interest due on the deficiency.
2 The entire underpayment of income tax is a substantial
underpayment attributable to tax-motivated transactions under
sec. 6621(c).
3 For 1982 respondent, in an amendment to answer, determined
an addition to tax under section 6661 of $1,333.75 as an
alternative to the addition to tax under section 6659 shown.
The issues remaining for our consideration concern whether
petitioner is liable for additions to tax under section 6653(a)1
for 1980; under section 6653(a)(1) and (2) for 1981, 1982, and
1983; and for increased interest under section 6621(c) for 1980,
1981, 1982, and 1983. In an amendment to answer, respondent
alleged that petitioner was liable for an addition to tax under
section 6661 for 1982. That addition to tax remains in
controversy. The parties stipulated that the facts and
conclusions in the opinion rendered in Schillinger v.
1 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, unless otherwise
indicated.
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Last modified: May 25, 2011