- 8 - Utah I, supra, the test case, and by our opinions in Christensen v. Commissioner, T.C. Memo. 2001-185, Serfustini v. Commissioner, T.C. Memo. 2001-183, and Nilsen v. Commissioner, T.C. Memo. 2001- 163, in each of which we upheld negligence additions to tax relating to investments in Blythe II. No credible evidence in this case provides any legitimacy to petitioners’ investment in the Blythe II partnership. In light of the above, for each year in issue petitioners are liable for the negligence addition to tax under section 6653(a), (a)(1), and (a)(2). To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011