Michael G. Harvey and Penny B. Harvey, (2001)

Extract

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Michael G. Harvey and Penny B. Harvey, (2001)

T.C. Memo. 2001-16

UNITED STATES TAX COURT MICHAEL G. HARVEY AND PENNY B. HARVEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9527-99. Filed January 25, 2001.

Joel N. Crouch and Sarah Q. Qureshi, for petitioners. Rodney J. Bartlett, for respondent.

MEMORANDUM OPINION DINAN, Special Trial Judge: Respondent determined that petitioner was liable for the following additions to tax for taxable year 1982: $452.25 under section 6653(a)(1), 50 percent of the interest due on a $9,045 deficiency under section 6653(a)(2), and $2,261.25 under section 6661. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.

The issues for decision are: (1) Whether petitioners are liable for additions to tax for negligence under section 6653(a), and (2) whether petitioners are liable for the addition to tax for a substantial understatement under section 6661. The issues in this case concern the participation of petitioner husband (Mr. Harvey or petitioner) as a ...

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