Elliot G. Steinberg - Page 2




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                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               COUVILLION, Special Trial Judge:  The matter before the                
          Court is an order to petitioner to show cause why a decision                
          should not be entered in this case in accordance with an                    
          agreement of the parties with respect to the deficiencies in tax,           
          the additions to tax, and the increased interest under section              
          6621(c).2                                                                   
               In a notice of deficiency, respondent determined the                   
          following deficiencies and additions to tax with respect to                 
          petitioner's 1980 and 1981 tax years:                                       

                                                  Addition to Tax                     
               Year           Deficiency          Sec. 6653(a)                        
               1980           $364,191.06         $18,210                             
               1981           334,735.66          16,7371                             
                    1For 1981, the addition to tax is under sec.                      
                    6653(a)(1) for the amount shown, plus, under                      
                    sec. 6653(a)(2), 50% of the underpayment                          
                    attributable to negligence or intentional                         
                    disregard of rules or regulations.                                

          In addition, respondent determined that the underpayments for               
          each year were substantial underpayments attributable to tax-               
          motivated transactions, and, accordingly, such underpayments were           
          subject to the increased rate of interest under section 6621(c).            




               2    Unless otherwise indicated, section references are to             
          the Internal Revenue Code in effect for the years at issue.                 




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