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Background
Petitioner resided in Novi, Michigan, when he filed the
petition. This case is part of respondent's tax shelter
litigation project entitled "Scheer". The Scheer litigation
project involves a partnership organized to purchase and market
video tapes. By notice of deficiency dated February 18, 1988,
respondent determined deficiencies in, additions to, and
increased interest on petitioner's 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) Sec.
6661
1981 $ 6,435 $322 1 $1,844 2 ---
1982 11,245 562 1 2,885 2 $407
1 50% of the interest due on the deficiency.
2 120% of the interest payable under sec. 6601.
In the stipulation, petitioner 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.
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Last modified: May 25, 2011