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Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $351 * $1,755
* 50 percent of the interest on $7,020.
The notice also included a statement that interest would accrue
and be assessed at 120 percent of the underpayment rate in
accordance with section 6621(c). The additions to tax resulted
from a final partnership proceeding involving a jojoba plant
venture known as Cal-Neva Partners (Cal-Neva). Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioners resided in Georgia at the time that they filed
their petition. In 1982, William R. Bass (petitioner) was
employed by Lockheed Corp. as an accountant, and Betty O. Bass
was employed by the Institute of Basic Youth Conflict as a
typist.
On or about December 23, 1982, petitioners paid $5,000 for a
limited partnership interest in Cal-Neva. The $5,000 was paid in
reliance on representations by two persons associated with Cal-
Neva whom petitioner met during a business trip to Nevada.
Petitioner did not consult any independent persons regarding the
viability of the jojoba plant venture or the claimed tax
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Last modified: March 27, 2008