- 5 -
petitioners are liable for the additions to tax under section
6659 for underpayments of tax attributable to valuation
overstatement; and (5) whether petitioners are liable for
increased interest under section 6621(c).
FINDINGS OF FACT
Some of the facts have been stipulated in each case and are
so found. The stipulated facts and attached exhibits are
incorporated in the respective cases by this reference.
Petitioners resided in Hammond, Indiana, when their
petitions were filed. During 1981 Wilson was a professional
football player for the New Orleans Saints. During 1978, 1979,
and 1981, Sorey was a professional football player for the
Chicago Bears.
Petitioners are limited partners in Efron Investors (EI),
which is a limited partner in the Clearwater limited partnership.
The Clearwater limited partnership is the same recycling
partnership that we considered in Provizer v. Commissioner,
supra. The underlying deficiencies in these cases resulted from
respondent's disallowance of claimed losses and tax credits that
were passed through both Clearwater and EI to petitioners.
Petitioners have stipulated substantially the same facts
concerning the underlying transactions as we found in Provizer v.
Commissioner, supra.3 Those facts may be summarized as follows.
3
The parties did not stipulate certain facts concerning the
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011