- 2 -
Additions to Tax and Penalties
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $173,817 $130,363 1 $43,454
Sec. 6653(b)(1) Sec. 6661
1988 53,937 $40,453 $13,484
Sec. 6651(a)(1) Sec. 6663
1989 73,279 $13,792 $54,959
Sec. 6654 Sec. 6662(c)
1990 124,891 $8,057 $24,978
150 percent of the interest due on $173,817.
After concessions,2 the primary issue for decision is whether
petitioner Donna A. Rowe is entitled to relief from joint
liability pursuant to section 60153 with respect to the following
omitted income and erroneous deduction items giving rise to
deficiencies: (1) Distribution proceeds from a retirement
account in petitioner’s name; (2) capital gain income from the
sale of jointly titled property; (3) mortgage interest deductions
on jointly titled property; (4) losses related to a farming
activity; and (5) charitable contribution deductions.
Additionally, we must decide whether petitioner Donna A. Rowe is
1(...continued)
sec. 6663 for the taxable year 1989, relate only to petitioner
John A. Rowe.
2See appendix.
3References to sec. 6015 are to that section as added to the
Internal Revenue Code by the Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,
112 Stat. 734. Unless otherwise indicated, all other section
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011