- 2 -
and Rules 180, 181, and 183. All section references are to the
Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure. The Court agrees with and
adopts the opinion of the Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: In so-called affected items
notices of deficiency, respondent determined additions to tax
with respect to petitioners’ Federal income taxes for the years
and in the amounts as shown below:
Oreland A. and Lucille S. Thornsjo
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $897 -0- $5,381
1980 824 -0- 4,943
1982 545 1 1,226
1983 14 1 -0-
Donald L. and Diane J. Woolf
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $1,012 -0- $6,070
1982 1,393 1 5,480
1983 21 1 -0-
Lawrence J. and Dorothy A. Furlong
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $1,878 -0- $8,721
1Fifty percent of the interest payable with respect to the
portion of the underpayment that is attributable to negligence.
The underpayments were determined and assessed pursuant to a
partnership-level proceeding. See secs. 6231-6233. With regard
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