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6653(b)(1)(A), and a related time-sensitive addition to tax under
section 6653(b)(1)(B).2 In an amended answer, respondent
asserted an increase in the deficiency of $560,000, a related
$420,000 addition to tax under section 6653(b)(1)(A), and a
related time-sensitive addition to tax under section
6653(b)(1)(B).
We must decide the following five issues as to 1986:
1. Whether respondent arbitrarily or erroneously determined
that petitioners failed to report net capital gains of
$2,341,878. We hold that he did not;
2. whether petitioners failed to report other income of
$2.8 million from the sale of securities. We hold that they did;
3. whether petitioners are liable for additions to tax
under section 6653(b)(1)(A) and (B), and, if so, whether section
6501(c)(1) applies to annul the 3-year period of limitations
under section 6501(a)(1). We hold that they are and that section
6501(c)(1) annuls the 3-year period of limitations;
4. whether respondent’s determination is barred by judicial
or equitable estoppel. We hold that it is not; and
5. whether petitioner Ingrid Doorn Ford (Ms. Ford) is
entitled under section 6015(b) to full or apportioned relief from
2 Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the relevant years, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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