- 12 - OPINION ........................... 592 Issue 37. Whether IRA Is Liable for the Section 6651(a)(1) Addition to Tax for 1980 ................ 596 OPINION ........................... 596 Issue 38. Whether IRA Is Liable for the Section 6653(a) Additions to Tax for 1980, and 1982 Through 1988 .... 597 OPINION ........................... 597 Issue 39. Whether IRA Is Liable for the Section 6659(a) Additions to Tax for 1982 and 1983 ........... 601 OPINION ........................... 601 Issue 40. Whether IRA Is Liable for the Section 6661 Additions to Tax for 1983 Through 1988 ......... 602 OPINION ........................... 602 Issue 41. Whether IRA Is Liable for the Section 6662(a) Accuracy-Related Penalty for 1989 ........... 606 OPINION ........................... 606 MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge: These consolidated cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. 2 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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