Daniel C. Greer and Winnie L. Greer - Page 2
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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
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Last modified: November 10, 2007