-435-
appealed and is otherwise final. See secs. 7481(a)(1), 7483.
Consequently, we need not consider this issue.
Issue XXIV. Additions to Tax and Related Matters
OPINION
In some of the notices of deficiency issued to the Kanters
and/or in amended pleadings filed in the Kanters’ cases,
respondent determined (as an alternative to respondent’s
determination the Kanters were liable for additions to tax for
fraud) that the Kanters were liable for additions to tax under
section 6653 (negligence), section 6659 (substantial valuation
overstatement), section 6661 (substantial understatement of tax),
and increased interest under section 6621(c).
The STJ report, at 265-293, recommended holding (1) the
Kanters were liable for additions to tax under sections 6653,
6659, and 6661 for the years in question, and (2) the Kanters
were liable for increased interest for 1980, 1984, 1986, and
1987.
Inasmuch as respondent asserted these additions to tax
against Kanter strictly as alternatives to respondent’s assertion
of the fraud additions (which we sustained above with regard to
income Kanter earned from The Five), we need not consider the
alternative additions to tax.
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