- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011