Donald J. Barnes and Beverly A. Edwards, f.k.a. Beverly A. Barnes - Page 20

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               Next, respondent reserved hearsay objections to Exhibits               
          400-P, 401-P, 405-P, and 478-P.  We need not address these                  
          objections, however, because they were withdrawn by respondent in           
          his opening brief.                                                          
               Finally, respondent reserved an objection to Exhibit 402-P             
          on the grounds that the exhibit is incomplete.  Again, while the            
          incomplete nature of the document affects the weight that it is             
          accorded in our findings, we overrule respondent’s objection and            
          hold that the exhibit is admissible.  See, e.g., Goichman v.                
          Commissioner, T.C. Memo. 1987-489 n.12.                                     
          II. Negligence                                                              
               With respect to each of the years in issue, section 6653               
          imposes one or more additions to tax on certain underpayments               
          attributable to negligence or intentional disregard of rules and            
          regulations.  With respect to petitioner’s taxable years 1978,              
          1979, and 1980, the addition to tax under section 6653(a) is                
          equal to 5 percent of the entire amount of an underpayment if any           
          part of the underpayment is due to negligence or intentional                
          disregard of rules or regulations.  With respect to petitioner’s            
          taxable year 1981, the addition to tax under section 6653(a)(1)             
          is the same as that imposed under the former section 6653(a).               
          However, with respect to that year, section 6653(a)(2) provides             
          for a further addition to tax equal to 50 percent of the interest           
          due on only that portion of the underpayment that is attributable           






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