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Additions to Tax
Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661(a)
$3,351.50 50 percent of the $16,757.50
interest due on
$67,030
The issue for decision is whether petitioner is liable for these
additions to tax. Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for 1983,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Tarzana, California, at the time he filed
his petition.
Petitioner is a tax attorney licensed to practice law in
California and Illinois. He received his law degree from the
University of Chicago Law School in 1962 and has been certified
as a specialist in tax law by the California Board of Legal
Specialization. From 1964 to 1974, he was employed by the
Internal Revenue Service (IRS), Office of Chief Counsel, where he
litigated numerous tax shelter cases. Some of these cases
involved tax-motivated transactions promoted by Harry Margolis.
In 1974, he served briefly as the Staff Assistant to the IRS
Regional Counsel for the Western Region. Following his tenure at
the IRS, he was hired as an attorney at the law firm of Levenfeld
& Kantor.
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Last modified: May 25, 2011