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determined in the notice of deficiency with respect to 1980-82:
Additions to tax and increased interest
Year Deficiency Sec. 6659 Sec. 6661 Sec. 6621(d)
1980 $27,920 -- -- $33,970
1981 $45,294 $13,588 -- $67,177
1982 $70,920 $15,918 $4,465 $53,749
With respect to 1982, respondent subsequently abated the
additions to tax under sections 6659 and 6661.
The Hendrickses began making payments shortly after the
assessment was made, paying the balance due for 1980 in full by
October 13, 1987. The liability for 1981 was paid in full by
December 1, 1989, and the liability for 1982 was paid in full by
August 27, 1993. Over the years 46 payments in varying amounts
were made totaling $387,903, the moneys being derived, in part,
from the sale of several of the condominiums.
On October 11, 1985, the same day the Hendrickses received
the notice of deficiency for 1980-82, respondent sent a letter to
Mr. Hendricks with respect to 1983, informing him that Boulder
Oil and Gas was being examined under the administrative
procedures enacted by the Tax Equity and Fiscal Responsibility
Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 324. Mr. Hendricks
received this letter at his place of business and did not take
the letter home. On April 25, 1988, respondent mailed a letter
to the Hendrickses at their home address, which stated that
respondent was proposing adjustment to their joint 1983 tax
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