Pamela Osowski - Page 2




                                        - 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 investment             





Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011