- 2 - Respondent determined that petitioners are liable for an addition to tax for negligence under section 6653(a)(2) for 1982. The only issue for decision is whether petitioners are liable for the addition to tax for negligence pursuant to section 6653(a)(2) for 1982 in the amount of 50 percent of the interest due on the underlying deficiency of $6,479,2 which respondent computed in connection with the disallowance of research and development expenditures deducted in 1982 by Jojoba Research Partners, Hawaii, a limited partnership. Background Some of the facts have been stipulated and are so found. We incorporate the stipulation of facts by this reference. Petitioners resided in Honolulu, Hawaii, on the date the petition was filed. Hereinafter, references to petitioner are to Rodney M. Fujiyama. Petitioner graduated from law school and has been licensed to practice law since 1970. Petitioner’s legal practice focuses primarily on business transaction planning. Petitioner does not practice tax law and has very little tax experience. When one of petitioner’s clients requires tax advice, petitioner engages the services of a national or local accounting firm to assist him. 2In his notice of deficiency, respondent determined that petitioners are liable for a negligence penalty in the amount of 50 percent of the interest due on $13,367. Respondent conceded in his trial memorandum that the penalty should be limited to 50 percent of the interest due on $6,479.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011