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Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $517 * $2,585
1983 20 ** –--
* Fifty percent of the interest due on $10,340.
** Fifty percent of the interest due on $393.
The issues for decision are: (1) Whether, for 1982 and 1983,
petitioner is liable for the additions to tax under section
6653(a)(1) and (2) for negligence, and (2) whether, for 1982,
petitioner is liable for the addition to tax under section 6661
for a substantial understatement of tax. The issues in this case
relate to the participation of petitioner as a limited partner in
a partnership known as Blythe Jojoba I Research, Ltd. (Blythe I
or the partnership).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was La Jolla, California.
Petitioner is a medical doctor specializing in dermatology.
Petitioner has been engaged in the private practice of
dermatology in the San Diego, California, area since 1980. For
approximately 20 years prior to 1980, petitioner worked as a
physician in the U.S. Navy. Petitioner was born and raised in
the U.S. Territory of Puerto Rico, where petitioner's father was
an accountant and a coffee bean and citron fruit farmer. While
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