- 2 - Respondent also determined that petitioner is liable for increased interest on underpayments attributable to tax-motivated transactions as defined in section 6621(c),1 for the entire underpayment of tax for 1980. The sole issue for our decision is whether the statutory periods of limitations for assessing and collecting the deficiencies in, and additions to, petitioner's Federal income taxes for 1980 and 1981 have expired.2 We hold they have not. Background Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. Petitioner is an attorney who resided in Rochester, Minnesota, at the time he filed his petition in this case. Petitioner filed his Federal income tax returns for the taxable years 1980 and 1981 on June 15, 1981, and October 15, 1Unless otherwise indicated, all 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. Sec. 6621(c), formerly sec. 6621(d), was redesignated pursuant to Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(c), 100 Stat. 2744. 2Petitioner asserts on brief that interest on the deficiency should be abated pursuant to sec. 6404(e). Consideration of petitioner's request for abatement of interest is premature, however, as there has been neither an assessment of interest nor a final determination by respondent not to abate the interest. See sec. 6404(e), (g), as currently in effect; see also Bourekis v. Commissioner, 110 T.C. 20, 26 (1998).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011