- 586 - Our findings and conclusions with respect to the following issues clearly show that portions of Kanter's underpayments of income taxes were attributable to negligence or intentional disregard of rules or regulations to the extent the 1986 through 1989 tax years are involved: (1) Commitment fees received by Century Industries (Issue 2); (2) income of the Bea Ritch Trusts (Issue 4); (3) interest deduction for 1986 (Issue 17); and (4) capital gains and losses (Issue 21). Also, Kanter conceded some adjustments but failed to address the additions to tax for negligence with respect thereto. Unlike the underpayments attributable to fraud with respect to the "Prudential Issues" or "The Five", only the negligence additions to tax apply to these issues. See sec. 6653(a)(2); sec. 6653(b)(2). Issue 34. Whether the Kanters Are Liable for the Section 6659 Addition to Tax for 1981 OPINION This issue relates to the Kanters' liability for the addition to tax under section 6659 for substantial valuation overstatement with respect to a $4,283 loss claimed from GLS Associates on their 1981 income tax return. We sustained respondent's disallowance of this loss (Issue 13). On their 1981 return, the Kanters also claimed an investment interest expense deduction relating to GLS Associates in the amount of $45,095, which respondent disallowed in the notice of deficiency. In a Stipulation of Settled Issues dated April 12, 1990, the KantersPage: Previous 576 577 578 579 580 581 582 583 584 585 586 587 588 589 590 591 592 593 594 595 Next
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