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Addition to Tax
Year Deficiency Sec. 6653(a)
1976 $5,635 ---
1977 8,100 ---
1978 7,258 $363
Respondent has also determined that petitioners are liable for
increased interest on underpayments attributable to a tax-
motivated transaction as defined in section 6621(c).1
After concessions, the issues for decision are: (1) Whether
the Oshtemo-Kalamazoo Associates partnership (Oshtemo-Kalamazoo),
in which petitioner Abraham Weiss was a general partner, engaged
in a cable television activity for profit, with the result that
petitioners should be allowed to claim their proportionate share
of the losses and investment tax credits generated by that
activity for the years in issue; (2) whether petitioners failed
to establish their ownership interests in the partnership, so as
to be entitled to the deductions or credits in question, or
whether the transactions were instead shams, devoid of substance;
(3) whether respondent may disallow the losses from Oshtemo-
Kalamazoo claimed as deductions on petitioners' tax returns for
the taxable years 1976, 1977, and 1978 without proof that
adjustments were made to the partnership returns of Oshtemo-
Kalamazoo; (4) whether petitioners are liable for the negligence
addition to tax pursuant to section 6653(a) for the taxable year
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011