Investment Research Associates - Page 43




                                       - 13 -                                         
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               COUVILLION, Special Trial Judge:  In these consolidated                
          cases, respondent determined deficiencies in petitioners' Federal           
          income taxes, additions to tax,3 penalties, and increased                   
          interest, as follows:                                                       
          Investment Research Associates, Ltd., and Subsidiaries                      
               Docket No. 43966-85:                                                   
          Addition to Tax                                                             
          Year          Deficiency          Sec. 6659(a)                              
          1979           $18,791               $5,637                                 
               Docket No. 45273-86:                                                   
                   Additions to Tax                                                   
          Year    Deficiency   Sec. 6653  Sec. 6659(a)  Sec. 6661                     
          1982     $174,225     $8,711      $49,154      $1,038                       








          3                                                                           
               With respect to the additions to tax under sec. 6653, as to            
          all of the cases before the Court, for the years 1979 and 1980,             
          the addition to tax is under sec. 6653(a).  For the years 1981              
          through 1985, the addition to tax is under sec. 6653(a)(1).  For            
          the years 1981 through 1985, respondent also determined the                 
          addition to tax under sec. 6653(a)(2), which is 50 percent of the           
          interest due on the underpayment of tax attributable to                     
          negligence or intentional disregard of rules or regulations.  For           
          the years 1986 and 1987, the addition to tax is under sec.                  
          6653(a)(1)(A), and the determined 50-percent interest due on the            
          underpayment is under sec. 6653(a)(1)(B).  For 1988, the addition           
          to tax is under sec. 6653(a)(1), and there is no corresponding              
          addition to tax for 50 percent of the interest due on the                   
          underpayment.  See Technical and Miscellaneous Revenue Act of               
          1988, Pub. L. 100-647, sec. 1015(b)(2)(A), 102 Stat. 3342, 3568,            
          applicable to returns the due date for which, without regard to             
          extensions, is after Dec. 31, 1988.                                         





Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011