- 3 -
After giving effect to petitioners’ concession,3 the issues
remaining for decision are:
1. Whether petitioners are liable for additions to tax
under sections 6654(a) and 6651(a)(2) in the section 6330 cases,
and section 6651(a)(1) in the section 6330 cases and the
deficiency case. We hold petitioners are liable for all those
additions;
2. whether petitioners are entitled to abatement of
interest on the tax liability reported on their 1997 return. We
hold petitioners are not entitled to any interest abatement;
3. whether petitioners are entitled to deductions for
casualty losses on their 1997 return in excess of the amounts
allowed in the notice of deficiency. We hold petitioners are not
entitled to any such deductions.
For clarity and convenience, following a statement of
general findings of fact, we set forth the findings of fact and
opinion with respect to each issue under a separate heading.
General Findings of Fact
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
3Petitioners have conceded respondent’s upward adjustment of
the casualty loss they claimed with respect to their vacation
house located in Baldwin County, Ala., on the Gulf of Mexico.
See infra notes 8 and 9.
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