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Schedule E, she reported two rental losses totaling $13,527.99,
two partnership losses totaling $24,184 (including her $23,174
distributive share of Yuma Mesa’s loss), and a gain from another
partnership of $14,457.
After examining Yuma Mesa’s partnership return for taxable
year 1982, respondent disallowed the $1,298,031 deduction claimed
as research and development costs and increased the partnership’s
income by a total of $1,307,781. Respondent’s determinations
were upheld in their entirety by this Court. Respondent
subsequently determined that petitioner’s portion of the
partnership level adjustment resulted in an $11,587 deficiency.
Respondent issued petitioner a statutory notice of deficiency
determining additions to tax under sections 6653(a)(1),
6653(a)(2), and 6661, in the respective amounts of $579, 50
percent of the interest due on an $11,587 deficiency, and $2,897.
The first issue for decision is whether petitioner is liable
for additions to tax for negligence under section 6653(a)(1) and
(2). Section 6653(a)(1) imposes an addition to tax equal to 5
percent of the underpayment of tax if any part of the
underpayment is attributable to negligence or intentional
disregard of rules or regulations. Section 6653(a)(2) provides
for a further addition to tax equal to 50 percent of the interest
due on the portion of the underpayment attributable to negligence
or intentional disregard of rules and regulations.
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