Charles A. Greene and Christine J. Greene - Page 13

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          partnership loss that petitioners had not eliminated on the                 
          amended return.  The assessment reflected a total tax liability             
          for 1983, in respect of partnership items relating to Mid                   
          Continent, of $23,194 less the $18,194 that petitioners had                 
          previously designated as tax and remitted with their amended                
               On December 29, 1993, and February 9, 1994, respondent                 
          mailed notices of deficiency to petitioners in which there were             
          determined additions to tax for negligence under section                    
          6653(a)(1) and (2) for the taxable years 1983 and 1984,                     
          respectively.  The additions to tax are affected items in that              
          they are based on tax owing by petitioners as a result of                   
          adjustments to partnership items appearing on Mid Continent’s               
          partnership returns for 1983 and 1984.                                      
               Petitioners argue that they are not subject to the additions           
          to tax for negligence because:  (1) The Internal Revenue Code               
          should not punish negligent investing, only negligence in                   
          reporting tax obligations; (2) they, unsophisticated investors,             
          relied in good faith upon the advice of a competent, independent            
          professional on an investment activity known to be risky; and (3)           
          if they are found to have been negligent, the payment of tax with           
          the amended return for 1983 eliminates or reduces the 1983 year             

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