- 2 - deficiency that petitioner was liable for the time sensitive addition to tax under section 6653(a)(2) and the increased rate of interest under section 6621(c). Following concessions by the parties, we must decide: 1. Whether petitioner is liable for an addition to tax under section 6659 equal to 30 percent of the deficiency arising from a disallowed investment tax credit and loss that petitioner claimed from a partnership named Grade Partners (Grade), and 2. Whether petitioner is liable for the increased rate of interest under section 6621(c) on the deficiency. We hold for respondent as to both issues. Section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties have filed with the Court a stipulation of facts and accompanying exhibits. We find the stipulated facts accordingly, and we set forth the relevant facts in this background section. We also set forth in this section facts which we find from the exhibits and from matters which petitioner admitted under Rule 90. Petitioner resided in New York, New York, when she petitioned the Court. Petitioner timely filed her 1981 Federal income tax return. She claimed thereon a $689 loss from Grade, a $9,380 investmentPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011