Charles R. Godwin et al. - Page 3

                                        - 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              
               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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