-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.Page: Previous 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 442 443 444 Next
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