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Background
Petitioners resided in Pittsburgh, Pennsylvania, when they
petitioned the Court. This case is part of respondent's tax
shelter litigation project entitled "Scheer". Scheer involves a
partnership organized to purchase and market video tapes. By
notice of deficiency dated January 27, 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) Sec.
6661
1981 $24,350.02$1,217.50 1 $6,945.76 2 ---
1982 24,586 1,229.30 1 5,310.60 2 $1,721
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;
2. The above adjustments, as specified in the
preamble, shall be redetermined by application of the
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