- 2 -
The Court agrees with and adopts the opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency, additions to tax, and additional interest with
respect to petitioners' Federal income taxes for the years and in
the amounts as shown below:
Docket No. 15253-87
Additional
Additions to Tax Interest
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659 6621(c)
1981 $7,747 $387 1 $2,277 2
Docket No. 24339-95
Additional
Additions to Tax Interest
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659 6621(c)
1982 -- 1,147 1 3,542 --
1983 -- 321 1 1,842 --
1984 -- 396 1 2,229 --
1 50 percent of the portion of the underpayment that is
attributable to negligence. For 1982 through 1984, the
underpayments ($22,947 for 1982, $6,141 for 1983, and $7,431 for
1984) were determined and assessed pursuant to a partnership-
level proceeding. See secs. 6231-6233. In the present cases,
respondent determined that the entire underpayment for each of
the years in issue is attributable to negligence.
2 Interest on the entire underpayment to be computed at 120
percent of the rate otherwise applicable under sec. 6621(a).
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