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Court Rules of Practice and Procedure. The Court agrees with and
adopts the opinion of the Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: In so-called affected items
notices of deficiency, respondent determined additions to tax
with respect to petitioners’ Federal income taxes for the years
and in the amounts as shown below:
Keith E. & Marilyn B. West
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $808 -0- $4,848
1982 1,607 1 8,467
1983 25 1 -0-
1984 10 1 -0-
Warren S. & Elizabeth A. West
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $953 -0- $5,717
1980 204 -0- 1,191
1982 1,239 1 4,787
1 Fifty percent of the interest payable with respect to the
portion of the underpayment that is attributable to negligence.
The underpayments were determined and assessed pursuant to a
partnership-level proceeding. See secs. 6231-6233. With regard
to petitioners Keith E. and Marilyn B. West, respondent
determined underpayments attributable to negligence of $32,147,
$498, and $207 for 1982, 1983, and 1984, respectively. With
regard to petitioners Warren S. and Elizabeth A. West, respondent
determined an underpayment attributable to negligence for 1982 of
$24,772.
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