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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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Last modified: May 25, 2011