Roger W. and Kathleen Stoy - Page 2

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          Background                                                                  
               Petitioners resided in Millersville, Maryland, when they               
          petitioned the Court.  This case is part of respondent's tax                
          shelter litigation project entitled "Scheer".  Scheer involves a            
          partnership organized by Lawrence Scheer to purchase and market             
          video tapes.  By notice of deficiency dated May 6, 1987,                    
          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 $13,173   $659           1         $3,952      2                       
          1982 10,580    529            1         3,174       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.                                                              




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