- 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