Jackie H. Hunt - Page 7




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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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