- 2 - Respondent determined additions to petitioner's Federal income tax for the years 1979 through 1982 as follows: Additions to Tax Year Sec. 6653(a)(1) Sec. 6653(a)(2)1 Sec. 6659 1979 $211 applies $1,266 1980 189 applies 1,137 1981 22 applies 131 1982 221 applies 742 1. Fifty percent of the interest due on the portion of the underpayment attributable to negligence for the years 1979, 1980, 1981, and 1982. In a Stipulation of Settled Issues the parties agree that "all issues that relate to the additions to tax" have been conceded except liability for the negligence additions to tax for the taxable years 1979 through 1982 and the applicability of section 6659 "for the taxable year 1981." The stipulation limiting the contest of the application of section 6659 to the 1981 year is by way of a handwritten addendum to paragraph 2 of the stipulation agreement. At trial, respondent's counsel read into the record the stipulated paragraph with the added language. Although petitioner's counsel made a correction to the reading of the paragraph, it was not with respect to the language addressing the year of the 6659 addition.2 In view of the record, we interpret paragraph 2 of the stipulation of settled issues as a concession by petitioner of 2On brief, petitioner addressed the sec. 6659 addition only as it relates to the year 1981.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011