Robert Emmett Robertson, III - Page 2




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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CHABOT, Judge:  Respondent determined deficiencies in                  
          individual income tax and additions to tax under sections                   
          6651(a)(1)1 (late filing of tax return) and 6653(a) (negligence,            
          etc.) against petitioner as follows:                                        
                                          Additions to Tax                            
          Year Deficiency Sec. 6651 Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2)      
          1981   $11,194              $560                                            
          1982    14,406   $3,602                  $720      50% interest             
                                                              on $14,406              
          1983     2,843                            142      50% interest             
                                                                on 2,843              
          1984     1,212      165            61      50% interest                     
                                                                on 1,212              
          1985     6,332                           317      50% interest             
                                                                on 6,332              
               After concessions2 the issue for decision is whether a                 
          certain income item for 1981 and a certain income item for 1982             
          should be treated as income from trades or businesses or as                 
          interest income, not from trades or businesses.                             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated; the stipulations and           
          the stipulated exhibits are incorporated herein by this                     
          reference.                                                                  


               1Unless indicated otherwise, all section references are to             
          sections of the Internal Revenue Code of 1954 as in effect for              
          the years in issue.                                                         
               2The parties filed two sets of stipulations, with a total of           
          63 paragraphs, resolving numerous issues.  At trial, respondent             
          orally conceded all the additions to tax and all the remaining              
          matters in dispute, except for the issue for decision in this               
          opinion.                                                                    





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