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Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $1,047 * $5,234
1983 50 ** –--
* Fifty percent of the interest due on $20,933.
** Fifty percent of the interest due on $1,006.
The issues for decision are: (1) Whether, for 1982 and 1983,
petitioners are liable for the additions to tax under section
6653(a)(1) and (2) for negligence, and (2) whether, for 1982,
petitioners are liable for the addition to tax under section 6661
for a substantial understatement of tax. The issues in this case
relate to the participation of Don L. Christensen (petitioner) as
a limited partner in a partnership known as Blythe Jojoba II
Research, Ltd. (Blythe II or the partnership).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was Las Vegas, Nevada.
Petitioner is a medical doctor specializing in general
surgery. Petitioner has been practicing general surgery in Las
Vegas, Nevada, since 1965. When petitioner's investment adviser
retired, he referred petitioner to another financial adviser
named Gary Sheets (Mr. Sheets). At that time, Mr. Sheets began
advising petitioner on various financial matters and introduced
petitioner to numerous investment opportunities.
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