Arnold S. and Ellen K. Jacobs - Page 3

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            attributable to a tax-motivated transaction for purposes of                               
            computing the interest payable with respect to such amount,                               
            pursuant to section 6621(c).  With respect to the addition to tax                         
            under section 6653(a)(2), petitioners concede that the entire                             
            underpayment of income tax is due to negligence, but dispute the                          
            applicability of section 6653(a)(2).                                                      
                  The sole issue for decision is whether the effective date of                        
            section 6653(a)(2) precludes application of that section to a                             
            portion of the deficiency equal to three installments of                                  
            estimated tax paid during 1981.                                                           
                  The parties submitted this case fully stipulated.  The                              
            stipulated facts and attached exhibits are incorporated herein by                         
            this reference.  Petitioners resided in New York, New York, at                            
            the time their petition was filed.                                                        
                  On April 15, June 17, and September 18, 1981, petitioners                           
            made three payments of estimated tax for taxable year 1981, each                          
            in the amount of $13,000.2  Petitioners made a fourth and final                           
            payment of estimated tax for taxable year 1981 on January 18,                             
            1982, in the amount of $30,000.  On April 15, 1982, petitioners                           
            filed a Form 4868, Application for Automatic Extension of Time to                         
            File U.S. Individual Income Tax Return, and included a payment of                         
            $10,000.  After requesting another extension of time to file,                             


            2     Also on Apr. 15, 1981, an overpayment in the amount of                              
            $3,388 from the prior tax period was credited towards                                     
            petitioners' 1981 estimated tax.                                                          




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