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Taxable Year Additions to Tax
Docket No. Ending Sec. 6653(a)(1) Sec. 6653(a)(2)
11377-00 Feb. 29, 1984 $186 *
11378-00 Dec. 31, 1983 256 *
11383-00 Dec. 31, 1983 184 *
* 50% of the interest due on deficiencies of $3,712, $5,117,
and $3,672, respectively.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue.
The issue for decision is whether petitioners are liable for
each of the additions to tax determined by respondent.2
Background
Some of the facts have been stipulated and are so found.
The stipulations of fact and those attached exhibits which were
admitted into evidence are incorporated herein by this reference.
On the date the petitions were filed in these cases, petitioners
all resided in New Jersey.
Petitioners each invested in a venture known as Arid Land
Research Partners (“Arid Land” or “the partnership”) in December
1983. They all became involved with the partnership through Paul
Trimboli, an accountant and financial planner. Prior to the time
2In each of the petitions, petitioners argued that (1) the
notice of deficiency was issued “beyond the Statute of
Limitations”; (2) the notice “is invalid due to the fact that the
Commissioner failed to make a determination” after an examination
of facts particular to petitioners’ case; and (3) the
Commissioner failed to allow petitioners “their appeal rights
within the Internal Revenue Service”. Petitioners concede the
first issue. Petitioners did not address the remaining issues in
their briefs, and we therefore consider them to have been
abandoned and we need not address them here.
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