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Additions to Tax
Petitioners Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
Sann $192,666 $9,633.30 1 $54,582.60
Addington 63,137 3,156.85 1 18,840
Cohn 10,250 512.50 1 2,892.30
150 percent of the interest payable with respect to the portion of the
underpayment attributable to negligence. The additions to tax determined under
section 6653(a)(2) were calculated on the amount of $181,942 in the Sann case; on
the amount of $62,800 in the Addington case; and on the amount of $9,641 in the
Cohn case.
In another three notices of deficiency, issued on July 19, 1990,
in docket Nos. 22466-90 and 22399-90 (Sann and Addington,
respectively), and on July 20, 1990, in docket No. 21209-90,
(Cohn), respondent determined the following deficiencies in and
additions to petitioners' 1982 Federal income taxes:
Additions to Tax
Petitioners Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) 2Sec. 6659
Sann $94,403 $4,720 1 $23,030
Addington 44,317 2,215.85 1 10,649
Cohn 15,893 795 1 4,020
150 percent of the interest payable with respect to the portion of the
underpayment attributable to negligence. The additions to tax determined under
section 6653(a)(2) were calculated on the full amount of the deficiency in each
case. 2In the alternative to the sec. 6659 addition to tax, respondent determined
an addition to tax under sec. 6661 for substantial understatement of liability.
Respondent conceded the sec. 6661 additions to tax in the respective posttrial
briefs in each case.
In all six notices of deficiency, respondent also determined that
interest on the deficiencies accruing after December 31, 1984,
would be calculated at 120 percent of the statutory rate under
section 6621(c). In the posttrial brief for docket No. 4789-89
(Cohn), respondent asserted a lesser section 6659 addition to tax
in the amount of $2,447. We consider the section 6659 addition
to tax in docket No. 4789-89 to be accordingly reduced.
On July 1 and July 11, 1994, respondent filed motions for
leave to file amended answers in docket Nos. 4789-89 (Cohn) and
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