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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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