- 2 - subsequent section references are to the Internal Revenue Code in effect for the year in issue. Respondent determined that petitioners were liable for the following additions to tax for taxable year 1982: $523 under section 6653(a)(1); 50 percent of the interest due on an underpayment of $10,460 under section 6653(a)(2); and $2,615 under section 6661. The issues for decision are: (1) Whether petitioners are liable for additions to tax for negligence under section 6653(a); and (2) whether petitioners are liable for the addition to tax for a substantial understatement under section 6661. The issues in this case concern the participation of petitioners as limited partners in the Utah Jojoba I Research limited partnership (Utah I). Some of the facts in this case have been stipulated and are so found. Petitioners resided in Arvada, Colorado, at the time they filed their petition. In 1982, David Kessel (petitioner) was a pediatrician, and Ira Kaye Kessel (Mrs. Kessel) was a registered nurse. In 1979 or 1980, petitioner was referred by another physician to Elroy Jones (Mr. Jones) for his financial planning needs. Petitioners believed that Mr. Jones was an independent certified financial planner. During the times they made their investments, petitioners did not know that Mr. Jones worked for CoordinatedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011