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Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether petitioners are liable for
additions to tax for negligence or intentional disregard of rules
or regulations pursuant to section 6653(a)(1) and section
6653(a)(2) for the 1983 taxable year.
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time that they
filed their petition, petitioners resided in Ironton, Ohio.
On February 17, 1995, this Court entered a stipulated
decision in the underlying partnership proceeding, Anderson
Equip. Associates v. Commissioner, at docket No. 27745-89.
Pursuant to section 7481, that decision became final on May 18,
1995, and thereafter respondent assessed taxes against
petitioners for the 1981, 1982, 1983, and 1984 taxable years as
computational adjustments. The deficiency in the instant case is
attributable to adjustments in the underlying partnership
proceedings which resulted in automatic adjustments to
petitioners' income pursuant to the provisions of the Tax Equity
& Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat.
324.
On March 5, 1996, respondent issued a notice of deficiency
to petitioners for the 1981 taxable year. The question of
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