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Background
Petitioners John and Mary Anne Antoine resided in Bryan,
Texas, when they petitioned the Court. Petitioners Albert and
Louise Churik resided in New Kensington, Pennsylvania, when they
petitioned the Court. Petitioners John and Susan Ross resided in
Pittsburgh, Pennsylvania, when they petitioned the Court.1 This
case is part of respondent's tax shelter litigation project
entitled "Scheer". Scheer involves a partnership organized to
purchase and market video tapes. By notice of deficiency dated
June 2, 1987, respondent determined deficiencies in, additions
to, and increased interest on petitioners John and Mary Anne
Antoine's Federal income tax as follows:2
Additions to Tax and Increased Interest
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 Sec. 6621(c)
1982 $9,951 $497.55 1 $2,179.27
2
1 50% of the interest due on the deficiency.
2 120% of the interest payable under sec. 6601.
By notice of deficiency dated June 8, 1987, respondent determined
deficiencies in, additions to, and increased interest on
petitioners Albert and Louise Churik's Federal income tax as
follows:
1Although petitioners received separate deficiency notices,
they filed a collective petition.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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Last modified: May 25, 2011