- 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.
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