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This second stipulation resolved other issues concerning the
deficiencies at issue.
After additional concessions,3 the issues remaining for
decision are: (1) Whether petitioners are liable for additions
to tax for negligence or intentional disregard of rules or
regulations pursuant to section 6653(a) (or pursuant to section
6653(a)(1) and (2) for the years 1981 and 1982); (2) whether
petitioners are liable for increased interest on underpayments
attributable to a tax-motivated transaction pursuant to section
6621(c); and (3) whether petitioners are liable for the addition
to tax imposed under section 6661 for making a substantial
understatement for the year 1982.
FINDINGS OF FACT
The parties filed two stipulations of settlement of tax
shelter adjustments, a first stipulation of facts with attached
exhibits, a second stipulation of facts, and a third stipulation
of facts, with more attached exhibits. The facts reflected are
2(...continued)
deductions claimed by the taxpayers for losses incurred in
connection with that program.
3 In 1992, the parties filed a Stipulation of Settlement of Tax
Shelter Adjustment that resolved issues relating to the
Dorchester litigation project. The parties have also stipulated
that petitioner Diane C. Lincir is not entitled to "innocent
spouse" relief pursuant to sec. 6013(e) for the years at issue.
We also note that the parties' First Stipulation of Facts
indicates that the deficiencies for the years involved might be
affected by questions of net operating loss and investment tax
credit carrybacks from years not before the Court. We accept the
parties' representations that these carryback issues have been
resolved by their other agreements.
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