- 2 - Additions to Tax Under Secs. Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1982 $134,733.00 $6,736.65 1 $33,683.25 1983 176,099.00 8,804.95 1 44,024.75 1 50 percent of the interest due on the deficiency. Respondent has also determined increased interest under section 6621(c).1 The main issues for decision are: (1) Whether respondent timely issued notices of deficiency, and if so, (2) whether decedent was "protected against loss" within the meaning of section 465(b)(4) with respect to his pro rata share of partnership debt obligations arising from sale-leaseback transactions engaged in by a partnership, and (3) whether additions to tax under sections 6653(a) and 6661(a) and increased interest under section 6621(c) are applicable. This case was submitted fully stipulated. The stipulation of facts and the accompanying exhibits are incorporated herein by this reference. 1 Unless otherwise indicated, all statutory 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011