- 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.
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