Estate of Jack L. Bradley, Deceased, John S. Bradley, Successor Executor, C.T.A. - Page 2

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                                                                  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.                                                                                                                




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