- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011