- 2 -
Additions to Tax
Year Deficiency Sec. 6621(c) Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
Patty K. and Alvin C. Copeland
1979 $197,476 * $10,054 -- -- --
1980 203,319 * 9,927 -- -- --
1981 164,065 * -- $22,462 ** $80,086
1982 170,990 * –- 24,323 ** 67,608
1983 127,523 -0- -- -0- -0- -0-
Alvin C. Copeland
1985 $ 1,440 -0- -- -0- -0- -0-
* 120 percent of interest accruing after Dec. 31, 1984, on
portion of underpayment attributable to a tax-motivated
transaction.
** 50 percent of interest due on portion of underpayment
attributable to negligence.
This matter is before us on the parties’ cross-motions for
partial summary judgment with regard to the following legal
issues: (1) Whether, in analyzing claimed losses relating only to
the amount of “out-of-pocket” cash invested in limited
partnerships, the profit objective of the investments should be
measured at the partnership level or at the individual partner
level; and (2) whether increased interest under section 6621(c)
applies to petitioners’ tax deficiencies attributable to
petitioners’ limited partnership investments.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
Background
Many of the facts have been stipulated and are so found.
Petitioners resided in Metairie, Louisiana, at the time they
filed their petitions.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011