Donald A. Robins - Page 2

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                         Respondent determined additions to petitioner's Federal                                                              
                income taxes as follows:                                                                                                      
                                         Additions to Tax                                                                                     
                                         Sec.                     Sec.                                                                        
                                         6653(a)(1)/              6653(a)(2)/              Sec.                                               
                         Year            6653(a)(1)(A) 6653(a)(1)(B) 6661                                                                     
                         1985            $407                              1       $2,035                                                     
                         1986            241              2                                --                                                 
                         1 50 percent of the interest due on $8,138, which represents                                                         
                the portion of the underpayment attributable to negligence or                                                                 
                intentional disregard of rules or regulations.                                                                                
                         2 50 percent of the interest due on $4,825, which represents                                                         
                the portion of the underpayment attributable to negligence or                                                                 
                intentional disregard of rules or regulations.                                                                                
                         The Court must decide whether petitioner is liable for                                                               
                additions to tax under section 6653(a) for 1985 and 1986, and                                                                 
                whether petitioner is liable for an addition to tax under section                                                             
                6661(a) for 1985.                                                                                                             
                         Some of the facts have been stipulated and are so found.                                                             
                For clarity and convenience, our findings of fact and opinion                                                                 
                have been combined.  Petitioner resided in Fairport, New York,                                                                
                when his petition was filed.                                                                                                  
                         The issues in this case result from the Court's decision to                                                          
                sustain respondent's disallowance of charitable contribution                                                                  
                deductions claimed by Mount Mercy Associates, a limited                                                                       
                partnership, in 1985 and 1986.  See Mount Mercy Associates v.                                                                 
                Commissioner, T.C. Memo. 1994-83, affd. without published opinion                                                             
                50 F.3d 2 (2d Cir. 1995).  Our decision in Mount Mercy Associates                                                             




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