-2-
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $321 50 percent of $643
the interest due
on $6,426
The issues for decision are: (1) Whether the notice of
deficiency was issued after the period of limitations for the
assessment and collection of taxes for petitioner's 1982 tax year
expired; and (2) whether petitioner is liable for additions to
tax under section 6653(a)(1) and (2) and section 6661 for the
1982 tax year.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. Petitioner resided in
Reno, Nevada, at the time she filed her petition.
FINDINGS OF FACT
During 1982, petitioner worked for Cal-Sierra Financial
Services, and also for Spectra Financial Network (Spectra), a
financial planning company. Spectra was involved in the
marketing of limited partnership interests in Barbados #6 Ltd.
(Barbados). Petitioner invested in Barbados on the
recommendation of her then-boss, Kent Maerki.2 On her 1982
Federal income tax return, petitioner reported a $21,676 Schedule
2Mr. Maerki was not an attorney or a C.P.A., and no evidence
was offered regarding his professional credentials or his
knowledge of the Barbados venture.
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