- 2 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011