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Additions to Tax
Sec. Sec. Sec. Sec.
Year 6653(a) 6653(a)(1) 6653(a)(2) 6659
1979 $398 -– –- $2,388
1982 –- $1,660 1 7,366
1984 -- 363 1 1,852
150 percent of the interest payable with respect
to the portion of the underpayment that is attributable
to negligence. Respondent determined underpayments
attributable to negligence of $33,192 and $6,392 for
1982 and 1984, respectively.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions,1 the remaining issue for decision is
whether petitioners are liable for additions to tax for
negligence or intentional disregard of rules or regulations under
section 6653(a) for 1979, and section 6653(a)(1) and (2) for 1982
and 1984, respectively. We hold that petitioners are so liable.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulated facts and the attached exhibits are
1Petitioners concede that for each of the years in issue
they are liable for additions to tax under sec. 6659 for
underpayments of tax attributable to valuation overstatements in
the amounts determined by respondent. Also, petitioners have
abandoned their argument that assessment and collection of the
additions to tax for the years in issue are barred by the statute
of limitations because petitioners allegedly received no notice
of the entry of decision from their tax matters partner. See
Davenport Recycling Associates v. Commissioner, 220 F.3d 1255
(11th Cir. 2000), affg. T.C. Memo. 1998-347.
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Last modified: May 25, 2011