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the underpayment of tax shown on their 1997 Federal income tax
return.2 In docket No. 498-02 (the deficiency case), petitioners
dispute the deficiency and addition to tax determined by
respondent in their 1997 Federal income tax. The section 6330
cases and the deficiency case have been consolidated for trial,
briefing, and opinion.
In the section 6330 cases, respondent assessed the
underpayment (which has since been paid) of $281,340.82 in
petitioners’ 1997 joint Federal income tax shown on their 1997
return, additions to tax of $4,464.01 under section 6654(a) for
failure to pay estimated tax, $39,331.01 under section 6651(a)(1)
for late filing, and $15,848.72 under section 6651(a)(2) for late
payment, and interest of $21,984.63. The additions and interest
have not been paid and remain subject to respondent’s proposed
levy.
In the deficiency case, respondent determined a deficiency
of $208,625.87 in petitioners’ 1997 joint Federal income tax
attributable to the disallowance of claimed casualty losses and
an addition of $7,752.25 under section 6651(a)(1) for late
filing.
2Unless otherwise specified, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011