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and Procedure. The Court agrees with and adopts the opinion of
the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: In a so-called affected items
notice of deficiency, respondent determined additions to tax with
respect to petitioner’s 1982 Federal income tax of $6,115 under
section 6659 for valuation overstatement, $1,260 under section
6653(a)(1) for negligence, and under section 6653(a)(2) in an
amount equal to 50 percent of the interest due on $25,205, the
amount of the underpayment attributable to negligence. The
underpayment was determined pursuant to a partnership-level
proceeding. See secs. 6221-6233. After concessions,1 there are
two issues remaining for decision. The first issue is whether
petitioner is liable for the additions to tax under the
provisions of section 6653(a)(1) and (2) for negligence or
intentional disregard of rules or regulations. We hold that he
is liable for these additions to tax. The second issue is
whether petitioner is entitled to the benefits of a settlement
1 By stipulation, petitioner concedes the imposition of the
valuation overstatement addition to tax under sec. 6659. In
addition, petitioner concedes that the limitations period remains
open for assessment and collection of any penalties, additions to
tax, or interest attributable to partnership items for the 1982
tax year that may be held to be due from petitioner. Petitioner
previously raised the statute of limitations as a defense in his
petition.
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