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Additions to Tax
Sec. Amount
6653(a)(1) $ 2,225
6653(a)(2) *
6661 10,353
* 50 percent of interest due on related tax deficiency of $41,412.
After concessions, the threshold issue for decision is
whether resolution in this case of underlying issues (namely, a
statute of limitations defense and petitioners’ liability for
additions to tax) is controlled by resolution of similar
underlying issues in a related case.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Jupiter, Florida.
On December 29, 1982, petitioners invested $50,000 in a
limited partnership known as Barrister Equipment Associates
Series 112 (Barrister).
On Barrister’s 1982 Federal partnership tax return, ordinary
losses and investment tax credits were reported relating to works
of literature and to microcomputer disks. On audit of Barrister
in a partnership proceeding, respondent disallowed the claimed
losses and credits.
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Last modified: May 25, 2011