- 2 - Unless otherwise indicated, all 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. After concessions by respondent,1 we must decide the following issues:2 (1) Whether petitioners are entitled to deductions for interest that they paid with respect to delinquent Federal income taxes for 1984, 1985, 1986, 1987, and 1993; (2) whether petitioners are liable for the addition to tax under section 6651(a) for 1995; and (3) whether petitioners are liable for an accuracy-related penalty under section 6662(a) for 1996. Background The parties submitted the instant case fully stipulated pursuant to Rule 122. The stipulated facts are incorporated herein by reference and are found as facts in the instant case. Petitioners resided in Dallas, Texas, when they filed their petition. 1Respondent conceded the following items: (1) The adjustment in the notice of deficiency of $15,954 for alleged unreported interest income for 1995; (2) $26,136 of the total adjustment in the notice of deficiency for itemized deductions for 1996; and (3) the accuracy-related penalty under sec. 6662 in the amount of $12,968 for 1995. 2Certain computational issues also remain for 1995, resolution of which flows automatically from our resolution of the determinations in the notice that we address herein.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011