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MEMORANDUM OPINION
SWIFT, Judge: Respondent determined deficiencies in
petitioners’ Federal income taxes, additions to tax, and
increased interest, as follows:
Docket Nos. 37087-86 and 8910-88
John C. and Cornelia Vanderschraaf
Increased Interest and Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6621(c) 6653(a) 6653(a)(1) 6653(a)(2) 6659 6661
1980 $ 23,084 * $1,154 -- -- -- --
1981 21,939 * -- $1,097 ** $6,582 --
1982 12,184 * -- 609 ** 3,655 ***
Docket No. 6079-88
Estate of Donald R. Lawrenz, Sr., Deceased, and Ella A. Lawrenz
Increased Interest and Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6621(c) 6653(a) 6653(a)(1) 6653(a)(2) 6659
1980 $137,835 * $6,892 -- -- --
1981 200,227 * -- $10,011 ** $60,068
Docket No. 21729-88
Estate of Donald R. Lawrenz, Sr., Deceased
Increased Interest and Addition to Tax
Sec. Sec.
Year Deficiency 6621(c) 6653(a)
1979 $212,325 * $10,616
* 120 percent of interest accruing after Dec. 31, 1984,
on portion of the underpayment attributable to a tax-
motivated transaction.
** 50 percent of interest due on portion of underpayment
attributable to negligence.
*** 25 percent of underpayment due on portion attributable
to substantial understatement of tax.
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