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Additions to Tax
Year Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6659
1987 $738,211 $38,002 50 percent of the $214,997
interest due on
$2,629
Addition to Tax
Year Deficiency Sec. 6653(a)(1)
1988 $122 $639
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1989 $80,314 $17,750
The issues for decision are: (1) Whether petitioner is
entitled to a charitable contribution deduction under section
170(a)1 in the amount of $6 million for land he transferred to the
Commonwealth of Massachusetts (the Commonwealth) in 1986; (2)
whether petitioner is liable for additions to tax under section
6653(a) for the taxable years 1987 and 1988; (3) whether
petitioner is liable for an addition to tax under section 6659
for the taxable year 1987; and (4) whether petitioner is liable
for an accuracy-related penalty under section 6662(a) for the
taxable year 1989.2
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2In the notice of deficiency, respondent also determined
that petitioner is liable for additional interest in 1987 under
(continued...)
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Last modified: May 25, 2011