- 2 - Additions to Tax Sec.1 Sec. Sec. Year 6653(a)(1) 6653(a)(2) 36661 1983 $618 2$12,355 $3,089 1 Throughout this opinion and unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue. 2 The first page of the notice of deficiency mistakenly equates the amount of this addition to tax with the amount of the deficiency in income tax (see infra, subdivision “I” of the Findings of Fact). Prior to trial, respondent amended his answer to claim an increased addition to tax pursuant to sec. 6214(a). The increase, in the amount of $17,877, is purely computational in nature. 3 The first page of the notice of deficiency mistakenly references sec. 6662(d), which section is the successor to sec. 6661 and is applicable for returns the due date for which (determined without regard to extensions) is after December 31, 1989. See Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, sec. 7721(a), (c)(2), (d), 103 Stat. 2395-2400. After a concession by petitioners,1 the issues for decision are as follows: (1) Whether petitioners are liable for additions to tax under section 6653(a)(1) and (2) for negligence or intentional disregard of rules or regulations. We hold that petitioners are liable for such additions. (2) Whether petitioners are liable for the addition to tax under section 6661 for substantial understatement of tax liability. We hold that petitioners are liable for such 1 Petitioners concede that the notice of deficiency is valid. Cf. Scar v. Commissioner, 814 F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855 (1983).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011