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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.
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