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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 with respect to petitioners' Federal income tax for
1981 in the amount of $26,639, as well as additions to tax under
section 6659 in the amount of $7,992, under section 6653(a)(1) in
the amount of $1,344, and under section 6653(a)(2) in the amount
of 50 percent of the portion of the underpayment that is
attributable to negligence. Respondent also determined that
petitioners are liable for additional interest under section
6621(c) for interest on the entire underpayment to be computed at
120 percent of the rate otherwise applicable under section
6621(a).
The issues for decision are as follows:
(1) Whether petitioners are entitled to a partnership loss
and investment and energy credits flowing from the Sentinel EPE
recycler leasing program entered into by Clearwater Group. We
hold that they are not.
(...continued)
references are to the Internal Revenue Code in effect for the
taxable year in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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