- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011