- 2 -
Respondent determined that petitioners were liable for the
following additions to tax for the years 1982, 1983, 1984, and
1985:
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2)
1982 $250 *
1983 25 **
1984 15 ***
1985 17 ****
* Fifty percent of the interest due on $5,000.
** Fifty percent of the interest due on $298.
*** Fifty percent of the interest due on $294.
**** Fifty percent of the interest due on $427.
The issue for decision is whether, for 1982 through 1985,
petitioners are liable for the additions to tax shown above
relating to their participation as a limited partner in a
partnership known as Jojoba Research Partners, Hawaii (Jojoba
Hawaii 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 Colorado Springs, Colorado.
Petitioner husband is a salesman in the telecommunications
industry, and petitioner wife is a homemaker. During the years
at issue, petitioner husband worked in the telecommunications
industry, and petitioner wife worked as an administrative
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