- 3 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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