(7) Whether petitioner is liable for increased interest
under section 6621(c). We hold that he is.
(8) Whether petitioner is liable for a penalty for
maintaining a frivolous action under section 6673. We hold that
he is not.
FINDINGS OF FACT
The stipulation of facts and the attached exhibits are
incorporated herein. Petitioner resided in Toledo, Ohio, at the
time the petition was filed.
Petitioner has a bachelor of science degree in mechanical
engineering and was employed as an engineer for the Tosco Corp.
in its oil refinery at Bakersfield, California. Petitioner
received unemployment compensation in the amount of $5,312 in
1984. In 1984, after leaving Tosco, petitioner started a
business named J. Booker and Co., offering financial advice.
Encore Leasing
During 1983, petitioner investigated a number of tax
shelters before deciding to participate in the Encore Leasing Tax
Shelter Program as both an investor and a promoter. Petitioner
was the managing partner of BBG, Ltd.(BBG), which was composed of
petitioner and two other individuals. On December 27, 1984,
petitioner, acting on behalf of BBG, entered into a lease
transaction with Encore Leasing Corp. (Encore); the lease
indicates that BBG’s total investment in the program was $14,880.
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