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On May 31, 1995, respondent issued separate notices of
deficiency to petitioners for their 1979, 1980, and 1981 taxable
years (separately referred to as the 1979 notice, 1980 notice,
and 1981 notice, respectively). These notices underlie the
additions to tax at issue. The 1979 notice reflects respondent’s
determination that the portion of the disallowed investment tax
credit that petitioners carried back to 1979 results in an
underpayment of tax of $71 for 1979. The 1979 notice determined
that petitioners were liable for a $21 addition to tax under
section 6659 as a result of this underpayment. The 1980 notice
reflects respondent’s determination that the portion of the
disallowed investment tax credit that petitioners carried back to
1980 results in an underpayment in tax of $10,331 for 1980. The
1980 notice determined that petitioners were liable for a $3,099
addition to tax under section 6659 as a result of this
underpayment. The 1981 notice reflects respondent’s
determination that the portion of the disallowed investment tax
credit that petitioners carried back to 1981 results in an
underpayment in tax of $1,926 for 1981. The 1981 notice
determined that petitioners were liable for a $578 addition to
tax under section 6659 as a result of this underpayment.
Approximately 11 years before respondent issued these
notices of deficiency to petitioners, respondent issued a notice
of deficiency (the 1984 notice) to petitioners for 1980
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Last modified: May 25, 2011