- 2 -
Additions to Tax
Year Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1980 $60* –-- -–- —--
1982 --- $1,936 ** $9,682
1983 --- 40 *** -–-
* Based upon a claimed investment tax credit carryback from
1983.
** 50 percent of interest due on $38,726.
*** 50 percent of interest due on $805.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
After concessions, the remaining issue for decision is
whether petitioners are liable for the above additions to tax for
negligence under section 6653(a), (a)(1), and (a)(2), for 1980,
1982, and 1983.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated
herein by this reference.
At the time the petition was filed, petitioners resided in
Las Vegas, Nevada. Hereinafter, references to petitioner in the
singular are to Andrew J. Welch.
During the years in issue, petitioner was a successful
orthopedic surgeon practicing in Las Vegas, Nevada. During 1982
and 1983, petitioner’s medical practice was particularly
successful. Petitioner earned from his orthopedic practice
$649,177 in 1982 and $1,027,000 in 1983.
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