- 2 -2 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011