- 2 - Respondent determined additions to petitioners' Federal income tax as follows: Additions to Tax Tax Year Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6661 1986 $303 1 $1,514 1 50 percent of the interest due on $6,054. The issues for decision are: (1) Whether petitioners are liable for the additions to tax for negligence under section 6653(a)(1)(A) and (B); and (2) whether petitioners are liable for an addition to tax under section 6661. Some of the facts have been stipulated and are so found. For clarity and convenience, the findings of fact and opinion have been combined. Petitioner Michael J. Heckler (petitioner) resided in Kenmore, New York, and petitioner Charlotte A. Miska resided in Oyster Bay, New York, at the time they filed their petition. Petitioner and Miska were husband and wife during the taxable year in issue. As this Court previously observed in ruling on procedural matters in this case, our jurisdiction is limited to redetermining petitioners' liability for the additions to tax set forth in the affected items notice of deficiency. Heckler v. Commissioner, T.C. Memo. 1996-521. The notice of deficiency shows it was based on a corrected tax liability of $18,366 and that the tax shown on the return or as previously adjusted was $12,312.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011