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T.C. 6 (1999); Estate of Bartels v. Commissioner, 106
T.C. 430 (1996); and Estate of Mueller v. Commissioner,
101 T.C. 551 (1993), followed.
Stuart R. Singer, Michael R. Matthias, and Jeffrey P. Berg,
for petitioners.
David C. Holtz, for respondent.
MEMORANDUM OPINION
NIMS, Judge: Respondent determined the following
deficiencies and additions to tax with respect to decedents’
Federal income taxes for the taxable years 1981 and 1982:
Additions to Tax
Taxable Income Tax Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659
1981 $45,700 $2,285 50% of --
interest due
on $45,700
1982 7,604 -- -- $2,281
Respondent further determined that $19,539 and $7,604 of the
deficiencies for 1981 and 1982, respectively, were subject to the
increased interest charged on “substantial underpayments
attributable to tax motivated transactions” under section 6621(c)
(for 1982) or 6621(d) (for 1981).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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