Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 2

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          Increased Interest Pursuant to Former I.R.C. Section 6621(c).1              
          The issues raised by the parties' motions involve the scope of              
          the Court's jurisdiction in a so-called affected items                      
          proceeding.                                                                 
          Background                                                                  
               During 1986, Michael VonHeckler (petitioner) was a limited             
          partner in a partnership known as Irving & Co.  On their 1986               
          income tax return, petitioners reported a loss in the amount of             
          $15,432 representing their distributive share of a $183,184 loss            
          reported by Irving & Co. on its partnership return for 1986.                
               In early 1990, respondent issued a notice of deficiency to             
          petitioners determining a deficiency in, and additions to, their            
          Federal income tax for 1986.  The deficiency was based on                   
          respondent's determination disallowing Schedule C expenses and              
          itemized deductions (nonpartnership items) that petitioners                 
          reported on their 1986 return.  Petitioners filed a petition with           
          this Court, assigned docket No. 11547-90, seeking a                         
          redetermination of the deficiency and additions to tax.  On May             
          14, 1991, the Court entered a stipulated decision in docket No.             
          11547-90 that states that petitioners are liable for a deficiency           
          in tax in the amount of $1,747 for 1986.  The decision further              
          states that petitioners are not liable for additions to tax under           

               1  Unless otherwise noted, all section references are to the           
          Internal Revenue Code as amended.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  




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