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In separate notices of deficiency, respondent determined
that petitioners are liable for the following additions to tax
for the respective taxable years:
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661(a)
1983 $764 $15,285* $3,821
1984 18 359* ---
* 50 percent of the interest due on $15,285 and $359
for 1983 and 1984, respectively.
The issues for decision are whether petitioners are liable for
each of these additions to tax.1
Background
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Sparta, New Jersey, on the date the petition was filed in this
case.
Petitioner husband (Mr. McDonald) is a physician. During
1983 and 1984, he operated a sole proprietorship as a physician,
taking in gross receipts of $244,555 and $290,653 for a profit of
$172,252 and $204,704, respectively. He started this business in
1979, and approximately 1 year later he was referred to an
accountant named Paul Trimboli. Mr. Trimboli assisted
1In the petition, petitioners argued (1) that the deficiency
upon which the additions to tax are based is incorrect, and (2)
that petitioners “believe the statute of limitations has
expired.” Petitioners did not address these issues at trial or
in their posttrial memorandum of authorities. We therefore
consider them to have been abandoned, and we need not address
them here.
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