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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1985 $9,696 $2,424 $556
1986 5,077 1,117 236
1987 5,974 1,296 344
1988 8,206 1,952 514
1989 2,195 148 56
1990 10,448 2,144 71
1991 9,984 2,496 574
1992 6,556 1,639 286
1993 6,786 1,697 296
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The parties filed a stipulation of settled issues, which was
amended by agreement of the parties at trial. The sole issue
remaining after concessions is the amount and character of losses
sustained by petitioner on the foreclosure of various partnership
interests in 1987.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, the
supplemental stipulation of facts, and the attached exhibits. At
the time of filing the petition, petitioner resided in Round
Rock, Texas.
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