Robert P. Neumann and Sally A. Neumann - Page 2

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                    Additions to Tax                                                  
          Year      Sec. 6653(a)(1)     Sec. 6653(a)(2)     Sec. 6659                 
          1981           $587                *              $3,523                    
          1984           642                 **             3,854                     
          *  An amount equal to 50 percent of the interest due on $11,744.            
          ** An amount equal to 50 percent of the interest due on $12,846.            
          After concessions, the issues remaining for decision are:                   
          (1) Whether petitioners are liable for additions to tax for                 
          negligence under section 6653(a)(1) and (2); and (2) whether                
          petitioners are liable for additions to tax for valuation                   
          overstatement under section 6659.                                           
               This is an affected items proceeding which arises out of               
          petitioners' participation in the Alamo East Enterprises and                
          Alamo East Enterprises 1984 partnerships (the Alamo                         
          partnerships), which leased master recordings.  The parties                 
          stipulated that the Alamo partnerships were involved in the                 
          Encore Leasing Tax Shelter (Encore Leasing).  See Miller v.                 
          Commissioner, 104 T.C. 378 (1995).  Some of the other facts in              
          the instant case also have been stipulated and are so found.  For           
          clarity and convenience, the findings of fact and opinion have              
          been combined.                                                              
               Petitioners resided in Danville, California, at the time the           
          petition was filed.  During 1984, petitioner Robert P. Neumann              
          (petitioner) was the president of Thompson Electric, an                     
          electrical contracting firm located in San Ramon, California.               




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