- 4 - III. The Case Herein (Manko II) Respondent determined deficiencies in petitioners' Federal income taxes, additions to tax, and additional interest as follows: Additions to Tax and Additional Interest Sec. Sec. Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6653(b)(1) 6653(b)(2) 6661 6621(c) 1979 $2,676,752 $133,838 --- --- --- --- --- 2 1980 1,926,696 96,335 --- --- --- --- --- 2 1981 2,284,248 --- $114,212 1 --- --- --- 2 1982 1,794,143 --- 89,707 1 $897,072 1 $448,536 2 1983 1,649,568 --- 82,478 1 824,784 1 412,392 2 1 50 percent of the interest due on the deficiency. 2 120 percent of the interest due on the entire deficiency. Pursuant to the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(c)(1), 100 Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c). For 1982 and 1983, the negligence additions to tax were imposed with respect to the liability of Cynthia G. Manko, and the fraud additions to tax were imposed with respect to the liability of petitioner.1 All section references are to the Internal Revenue Code in effect for the years under consideration, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. The primary issue for decision is whether the settlement agreement applicable to petitioner's Arbitrage Management gains and losses in 1978 (Manko I) is likewise applicable to his Arbitrage Management gains and losses for the years in issue, 1979 through 1 The notice of deficiency also made adjustments for items unrelated to petitioner's interest in the partnerships, including an adjustment for unreported interest income for 1980. These unrelated issues have not been resolved.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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