Frances L. and Gary L. Rambacher - Page 8

          for tax years 1982 and 1983 for Series 98 to petitioners.                   
          Respondent also sent separate NBAPP's and FPAA's for the tax                
          years 1983 and 1984 of Series 124 to petitioners.                           
               The Court entered a stipulated decision in the underlying              
          partnership proceeding, Anderson Equip. Associates v.                       
          Commissioner, at docket No. 27745-89, on February 17, 1995.  The            
          decision provided that the losses claimed by Series 98 for 1982             
          and 1983 and Series 124 for 1983 and 1984 were not allowed, and             
          that the amount of qualified investment property held by Series             
          98 and Series 124 was zero for the aforementioned years as well.            
          Pursuant to section 7481, that decision became final on May 18,             
          1995, and, thereafter, respondent assessed taxes against                    
          petitioners for 1981, 1982, 1983, and 1984 as computational                 
          adjustments.  On March 5, 1996, respondent issued a notice of               
          deficiency to petitioner for 1981.                                          
               Section 6653(a)(1) provides for an addition to tax equal to            
          5 percent of any underpayment if any part of the underpayment is            
          due to negligence or intentional disregard of rules or                      
          regulations.  Section 6653(a)(2) provides for an addition to tax            
          in the amount of 50 percent of the interest payable on the                  
          portion of any underpayment of tax which is attributable to                 
          negligence or intentional disregard of rules or regulations.                
          Negligence is defined as the lack of due care or the failure to             
          do what a reasonable and ordinarily prudent person would do under           

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