- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011