- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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