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The Court agrees with and adopts the opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency, additions to tax, and additional interest with
respect to petitioners' Federal income tax for the taxable year
1981 in the amounts shown below:
Additions Additions Additions Additional
to Tax to tax to tax Interest
Sec. Sec. Sec. Sec.
Deficiency 6653(a)(1)1 6653(a)(2)1 6659 6621(c)
$28,169 $1,408 2 $8,451 3
1The references in the notice of deficiency are to
sec. 6653(a)(1)(A) and sec. 6653(a)(1)(B),
respectively. For the year in issue, the references
should have been to sec. 6653(a)(1) and sec.
6653(a)(2), respectively. However, there is no
substantive difference between sec. 6653(a)(1) and sec.
6653(a)(1)(A) and between sec. 6653(a)(2) and sec.
6653(a)(1)(B).
250 percent of the portion of the underpayment
that is attributable to negligence.
3Interest on the entire underpayment to be
computed at 120 percent of the rate otherwise
applicable under sec. 6621(a).
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