Donald J. Barnes and Beverly A. Edwards, f.k.a. Beverly A. Barnes - Page 2

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          case, and Rules 180, 181, and 183.1  The Court agrees with and              
          adopts the opinion of the Special Trial Judge, as set forth                 
          below.                                                                      
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               GOLDBERG, Special Trial Judge:  Respondent determined the              
          following deficiencies in petitioners’ Federal income taxes and             
          additions to tax for the respective taxable years:                          
                      Additions to Tax                                                
          Sec.       Sec.         Sec.       Sec.                                     
          Year   Deficiency   6653(a)1   6653(a)(1)2  6653(a)(2)2   6659              
          1978     $3,834      $192         n/a         n/a       $1,150              
          1979      4,420       221         n/a         n/a        1,326              
          1980      6,024       301         n/a         n/a        1,807              
          1981      8,143       n/a         $407         3        2,443               
               1As in effect for petitioners’ taxable years 1978, 1979, and           
          1980.                                                                       
               2As in effect for petitioners’ taxable year 1981.                      
               350 percent of the interest due on the deficiency of $8,143.           
          Respondent further determined that the entire amount of the                 
          deficiency for each year is subject to the increased rate of                
          interest charged on “substantial underpayments attributable to              
          tax motivated transactions” under section 6621(c)2.                         

          1Unless otherwise indicated, section references are to the                  
          Internal Revenue Code in effect during the years in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
          2References to sec. 6621(c) are to sec. 6621(c) as in effect                
          with respect to interest accruing after Dec. 31, 1986.  See Tax             
          Reform Act of 1986 (TRA 1986), Pub. L. 99-514, sec. 1511(d), 100            
          Stat. 2746.  For interest accruing before that date, but after              
          Dec. 31, 1984, a nearly identical provision was codified at sec.            
                                                             (continued...)           





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