2 Additions to Tax Additional Interest Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c) 1975 $ 4,847 $242 -- -- -- 1976 4,946 247 -- -- -- 1977 6,576 329 -- -- -- 1978 7,231 362 -- -- -- 1979 6,789 339 -- -- -- 1980 11,655 583 -- -- -- 1981 13,081 -- $654 1 $3,924 1982 9,751 -- 488 1 2,925 1 50 percent of the interest due to the underpayment of tax attributable to negligence or intentional disregard of rules and regulations. 2 120 percent of the interest due with respect to any substantial underpayment attributable to tax motivated transactions. After concessions reflected in the Stipulation of Settled Issues, filed March 24, 1995,2 the issue for decision is whether petitioners are entitled to an investment tax credit for the taxable year 1978, and, if so, in what amount, and whether they are entitled to any related carrybacks. This case was submitted fully stipulated pursuant to Rule 122. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Fair Oaks, California, at the 2 In their Stipulation of Settled Issues, the parties stipulated that, exclusive of the investment tax credit issue, there are deficiencies in petitioners' Federal income taxes as follows: Taxable Year Deficiency 1975 $4,847 1976 4,946 1977 6,727 1978 1,495 1979 1,549 1980 9,043 1981 8,750 1982 3,468 The parties further stipulated that there are no additions to tax under secs. 6653(a), 6653(a)(1), 6653(a)(2), and 6659 for any of the years in issue, and that no part of the deficiencies is a substantial underpayment for the purposes of computing interest payable with respect to such amounts pursuant to sec. 6621(c) (formerly sec. 6621(d)).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011