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ORDERED AND DECIDED: That there are deficiencies
in income taxes due from the petitioners [Mr. Hassell
and Ms. Hassell] as follows:
Deficiencies
Additions to the Tax
Taxable Income
Year Tax � 6653(a) � 6651 � 6661
1980 $18,642.64 none none none
1981 $18,493.26 none $2,638.84 none
1982 $23,411.00 none $1,510.00 $5,853.00
1983 $ 8,257.00 $ 474.55 $1,684.20 $2,064.00
1984 $37,344.50 $1,867.23 none $9,336.00
That there are additions to the tax due from the
petitioners for the taxable years 1983 and 1984, under
the provisions of I.R.C. � 6653(a)(2), equal to 50
percent of the statutory interest due on $8,257.00 and
$37,344.50 from April 15, 1984 and April 15, 1985,
respectively, to the date of assessment of tax, or, if
earlier, the date of payment, and
That the entire deficiencies in income tax due
from the petitioners for the taxable years 1980, 1981,
1982 and 1984 are substantial underpayments attribut-
able to tax motivated transactions for the purpose of
computing interest payable with respect to such
amounts, pursuant to I.R.C. section 6621(c), formerly
section 6621(d).
As reflected in petitioner’s individual master file literal
transcript (literal transcript) with respect to petitioner’s Form
1040 and certain other information for each of his taxable years
1980 through 1984, on various dates (respective assessment dates)
respondent assessed petitioner’s Federal income tax (tax), as
well as any additions to tax and interest as provided by law, for
each such year.
On November 22, 1993, petitioner and Ms. Hassell jointly
filed Form 1040 for their taxable year 1992 (1992 return). In
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Last modified: May 25, 2011