- 2 - Held: P-husband’s actions regarding the partnership interest were negligent, and R was not required to advise Ps regarding R’s investigation of the promoter. Therefore, the additions to tax under sec. 6653(a)(1) and (2), I.R.C., are sustained. Held, further, the remittance which was repaid by R is excluded from R’s computations of the addition to tax under sec. 6653(a)(2), I.R.C. Held further, the addition to tax under sec. 6659, I.R.C., is sustained. Joy L. Hall, Martin J. Horwitz, and John A. Freeman, for petitioner Daniel C. Greer Kenton Ball, for petitioner Winnie L. Greer. Aubrey C. Brown and Denise A. Diloreto, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: The issues in this case concern respondent’s determinations that petitioners are liable for additions to tax under sections 6653(a)(1) and (2), and 66591 on the deficiencies in tax resulting from the disallowance of a partnership loss and related tax credits claimed on petitioners’ 1982 joint Federal income tax return and carried back to petitioners’ joint Federal income tax returns for 1979 through 1981. These tax benefits 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007