Richard K. and Marilyn J. Phillips - Page 3




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                                               Additions to Tax               Additional
          Year DeficiencySec.      Sec.          Sec.        Sec.       Sec.    Interest
                         6651(a)   6653(a)   6653(a)(1)(B)    6659       6661   Sec. 6621(c)
          1980 $3,917    ––   –-        –-           –---        1                    
          1981      17   –-     -–   –- -–         --        --                       
          1982 1,248     -–   -–           –-     –-         -–            1          
          1983 11,334    $1,043     -–           –-–-         –-            1          
          1984 1,196     –-   -–           –-     -–         –-            1          
                         –--–           –-                                            
          1985 4,662     –-                       -–         –-            1          
          1986 8,068     139     -–           –-  -–         –-            1          
                         7,402    $2,760         2               1                    
          1987 54,708                        $16,412   $13,677                        
                                                                 1                    
          1988 52,048    8,981     2,670         -15,614    13,012                         
                                                          Penalties                   
                                   Sec.      Sec.      Sec.      Sec.                
                                  6662(h)    6662(e)  6662(d)   6662(c)              
          1989 $43,986   $4,008    $17,594   $8,797    $8,797    $8,797               
          1990 25,515    4,697     6,593     3,296     5,103     5,103                
          1991 41,240    7,435     16,238    8,119     8,248     8,248                
          1992 222,282   10,792    88,913    44,456    44,456    44,456               
          1                                                                           
               Respondent determined that interest is to be computed at 120 percent of the interest
          payable under sec. 6601 with respect to any substantial underpayment attributable to tax-
          motivated transactions.                                                     
          2    Respondent determined that an additional amount is to be computed equal to 50 percent of
          the interest attributable to the entire 1987 underpayment pursuant to sec. 6653(a)(1)(B).
               After concessions, the sole issue to be decided is whether             
          the periods of limitations for the years in issue expired before            
          the issuance of the final partnership administrative adjustments            
          (FPAA's).  The resolution of this issue depends upon whether                
          Walter J. Hoyt III, as tax matters partner for the partnerships             
          involved herein, validly executed various Forms 872, Consent to             
          Extend the Time to Assess Tax.                                              
               This case was submitted fully stipulated pursuant to Rule              
          122.  The stipulations of facts and the attached exhibits are               
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioners lived in Shell Beach, California.                    
               In 1983, petitioners became limited partners in the                    
          Shorthorn Genetic Engineering 1983-2 partnership (SGE 83-2) and             
          claimed losses and investment tax carrybacks to the 1980, 1981,             






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