- 2 - Respondent has also determined increased interest under section 6621(c).1 The main issues for decision are: (1) Whether petitioners were “protected against loss” within the meaning of section 465(b)(4) with respect to their pro rata share of partnership debt obligations arising from sale-leaseback transactions engaged in by a partnership, and (2) whether additions to tax under sections 6653(a) and 6661(a) and increased interest under section 6621(c) are applicable. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference. Petitioners both resided in California when they filed the petition in the instant case. Petitioners timely filed joint Federal income tax returns for the taxable years 1985 and 1986. Petitioners deducted losses and investment interest expenses (the claimed deductions) relating to Hambrose Leasing 1985-4 (the partnership) in the following amounts: Year Loss Investment Interest 1985 $27,985 $1,107 1986 45,689 14,916 1 All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011