- 20 - 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objections to Exhibits 400-P, 401-P, 405-P, and 478-P. We need not address these objections, however, because they were withdrawn by respondent in his opening brief.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 attributablePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011