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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.
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