- 2 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011