- 2 - Respondent issued a so-called affected items notice of deficiency for the taxable year 1982. In the notice, respondent determined that petitioners were liable for (1) additions to tax for negligence under section 6653(a)(1) and (a)(2) in the amounts of $492 and 50 percent of the interest due on $9,835, respectively, and (2) an addition to tax for valuation overstatement under section 6659 in the amount of $2,436. After concessions by petitioners,2 the issues for decision are as follows: (1) Whether petitioners are liable for additions to tax for negligence or intentional disregard of rules or regulations under section 6653(a)(1) and (2). We hold that they are not. (2) Whether petitioners are liable for the addition to tax for underpayment of tax attributable to valuation overstatement under section 6659. We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated, and they are so found. Petitioners resided in Toms River, New Jersey, at the time that their petition was filed with the Court. During the year in issue, petitioners were both 55 years old. During the preceding 30 years, petitioner husband (Mr. 2 Petitioners concede that partnership assets valued at $1,750,000 did not have a value exceeding $50,000. Further, petitioners raised a statute of limitations issue in their petition, but petitioners appear to have abandoned that issue. Nevertheless, we observe that the notice of deficiency was timely issued. See sec. 6229(d), (g).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011