- 15 -
We hold that petitioners are liable for the section 6661
additions to tax for 1983 and 1984 as determined by respondent.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
previously found that the Barrister Equipment Associates Series
162 partnership, the partnership involved in the stipulated
decision, lacked economic substance and was a sham. Connell v.
Commissioner, T.C. Memo. 1996-349.
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