- 2 -
OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: In separate notices of
deficiency, respondent determined the following deficiencies and
additions to tax against petitioners for the years indicated:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6661
1985 $ 6,293 $ 314 * $1,573
1986 10,186 1509 *1 2,546
*50 percent of the interest due on the underpayment attributable to
negligence.
1These additions to tax, for 1986, are under sec. 6653(a)(1)(A) and (B).
Respondent also determined increased interest, under section
6621(c), for each of the years at issue.
The issues for decision are: (1) Whether respondent timely
issued the aforementioned notices of deficiency to petitioners,
and, if so, (2) whether petitioner William Kingston (petitioner)
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 petitioners are liable for the
additions to tax under sections 6653(a) and 6661(a) and the
increased interest under section 6621(c).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was West Bloomfield, Michigan.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011