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Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
1983 $142,520 $71,260 50 percent of $35,630
the interest due
on $142,520
1984 369,494 184,747 50 percent of 92,374
the interest due
on $191,310
1985 543,404 271,702 50 percent of 135,086
the interest due
on $412,774
Additions to Tax
Year Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)
1986 $111,494 $5,575 50 percent of the
interest due on
$111,494
Respondent's determination was based on the following items:
Unreported gross income;1 disallowance of a net operating loss
carryover;2 allowance of a deduction for two-earner married
couples;3 an increase in capital gains;4 and disallowances of
various deductions for business losses and expenses.5
1Respondent determined that petitioners had unreported gross
income of $384,750, $382,620, and $825,548 in 1983, 1984, and
1985, respectively.
2Respondent disallowed $88,236 of petitioners' 1983 net
operating loss carryover deduction.
3Respondent allowed a deduction for two-earner married
couples of $120 for 1983 pursuant to sec. 221.
4Respondent determined an increase in petitioners' capital
gains of $6,636 for 1983.
5Respondent disallowed deductions claimed by petitioners for
(continued...)
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Last modified: May 25, 2011