- 2 - Additions to Tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6621(c) Sec. 6659 1980 $ 480 $ 24 --- --- --- 1981 931 47 1 --- --- 1982 543 27 1 --- --- 1983 4,357 218 1 2 $1,121 1984 4,889 244 1 2 1,467 1 50 percent of the interest due on $931 for 1981, $543 for 1982, $3,735 for 1983, and $4,889 for 1984. 2 120 percent of the interest due on $3,735 for 1983, and $4,889 for 1984. Pursuant to the Tax Reform Act of 1986, sec. 1151(c)(1), Pub. L. 99-514, 100 Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c). The deficiencies in this case arise from the disallowance of Schedule E losses and investment tax credits claimed by petitioners with respect to their investment in two partnerships--Media Marketers Limited Partnership (Media Marketers) and Assured Communications Limited Partnership (Assured Communications)--both of which engaged in so-called jingle transactions that this Court determined lacked economic substance. See Pacific Sound Prod. Ltd. Partnership v. Commissioner, T.C. Memo. 1993-253. Petitioners concede the deficiencies. Moreover, the parties have reached a settlement with respect to the additions to tax. Petitioner Kathleen M. Pewitt (Mrs. Pewitt), however, contests her liability for tax, claiming that she is an innocent spouse. Thus, the sole issue to be resolved herein is whether Mrs. Pewitt is entitled to tax relief as an innocent spouse pursuant to section 6013(e). For the reasons discussed, we hold she is not.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011