- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011