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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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