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effect at the time of assignment and Rules 180, 181, and 183.1
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: In so-called affected items
notices of deficiency, respondent determined additions to tax to
petitioners’ Federal income taxes for the years and in the
amounts as shown below:
Additions to tax
Sec. Sec. Sec.
6653(a)(1) 6653(a)(2) 6659
Year
1982 $4,829 1 $23,100
1983 49 1
1984 22 1
1985 25 1
1 50 percent of the interest payable with
respect to the portion of the underpayment
which is attributable to negligence or
intentional disregard of rules or regulations.
The underpayments for the years in issue were
determined and assessed pursuant to a partnership-
level proceeding. See secs. 6221-6233. In the
present cases, respondent determined that the
entire underpayment for each of the years in
issue is attributable to negligence or intentional
disregard of rules or regulations.
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
taxable years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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