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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