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Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1982 $789 $18,278 $4,732
1983 540 10,545 3,242
Following a concession by respondent,1 the issues for decision
are: (1) Whether Hyman S. Zfass (petitioner) is liable for
additions to tax under section 6653(a)(1) and (2) for 1982 and
1983, and (2) whether petitioner is liable for additions to tax
under section 6659 for 1982 and 1983.
All section references are to the Internal Revenue Code for
the years under consideration. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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.
Background
Petitioners, husband and wife, resided in Richmond, Virginia,
at the time they filed their petition. Petitioners timely filed
1 The parties have stipulated that Mrs. Zfass was not
involved in the purchase of the partnership interest involved
herein and was unaware of the substantial understatements on the
1982 and 1983 tax returns. Respondent concedes that Mrs. Zfass
is an innocent spouse for both years in issue and hence not
liable for any of the additions to tax involved herein.
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Last modified: May 25, 2011