- 2 - Background Petitioners resided in Winter Haven, Florida, when they petitioned the Court. This case is part of respondent's tax shelter litigation project entitled "Scheer". The Scheer project involves a partnership organized by Lawrence Scheer to purchase and market video tapes. By notices of deficiency dated August 2, 1988, respondent determined deficiencies in, additions to, and increased interest on petitioners' Federal income tax as follows:1 Additions to Tax and Increased Interest Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 Sec. 6621(c) 1981 $10,316.29 $ 515.82 1 $1,956.70 2 1982 7,663.00 383.15 1 2,298.90 2 1 50% of the interest due on the deficiency. 2 120% of the interest payable under sec. 6601. In the stipulation, petitioners agreed to be bound by the test case entitled Pinto v. Commissioner, docket No. 17407-86. This Court entered a decision in the Pinto case on January 18, 1995. The stipulation provides: With respect to all adjustments in respondent's notice of deficiency relating to the Scheer Project tax shelter, more specifically, the limited partnership entitled Richard II, Ltd., the parties stipulate to the following terms of settlement: 1. THE ABOVE ADJUSTMENTS ARE THE ONLY ISSUES IN THIS CASE WITH RESPECT TO ALL PARTIES; 1Unless 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011