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