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Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $443 * $2,215
1983 10 ** –--
* Fifty percent of the interest due on $8,858.
** Fifty percent of the interest due on $201.
The issues for decision are: (1) Whether, for 1982 and
1983, petitioners are liable for the additions to tax under
section 6653(a)(1) and (2) for negligence, and (2) whether, for
1982, petitioners are liable for the addition to tax under
section 6661 for a substantial understatement of tax. The issues
in these cases relate to the participation of Richard E. Nilsen
(petitioner) as a limited partner in a partnership known as
Blythe Jojoba II Research, Ltd. (Blythe II 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 petitions were filed, petitioners'
legal residence was Henderson, Nevada.
Petitioner is a medical doctor specializing in family
practice medicine. Petitioner has been practicing family
medicine in Las Vegas, Nevada, since 1964. During 1963 or 1964,
when petitioner was a medical intern, he became acquainted with a
financial adviser named Gary Sheets (Mr. Sheets). At that time,
Mr. Sheets began advising petitioner on various financial matters
and introduced petitioner to numerous investment opportunities.
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