William and Arlene G. Kingston - Page 2

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                              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.                                            





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