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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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Last modified: May 25, 2011