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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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Last modified: May 25, 2011