- 2 -
Respondent determined that petitioners are liable for
additions to tax for taxable year 1983 under section 6653(a)(1)
and (2) in the respective amounts of $198.20 and 50 percent of
the interest due on a $3,964 deficiency. The issue for decision
is whether petitioners are liable for 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
Eatontown, New Jersey, on the date the petition was filed in this
case.
Petitioner husband (petitioner) has a bachelor’s degree and
a master’s degree in electrical engineering and a doctorate in
mathematics. In the year in issue, he was a full professor and
the chairman of computer science and mathematics at Monmouth
College. He has no academic background in finance or taxation
and took only one course in economics as an undergraduate. Prior
to the year in issue, petitioners had limited experience in
making investments.
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011