2
Herbert Stoller and William L. Bricker, Jr., for
petitioners.*
Steven R. Guest, Mark J. Miller, and Edward G. Langer, for
respondent.
OPINION
SWIFT, Judge: Respondent determined deficiencies in
petitioners’ Federal income taxes and increased interest as
follows:
Estate of Leon Israel, Jr., Deceased, and Audrey H. Israel
Increased Interest
Year Deficiency Sec. 6621(c)
1977 $ 9,837 *
1979 14,442 *
1980 62,482 *
* 120 percent of interest accruing after Dec. 31,
1984, on portion of the underpayment attributable
to a tax-motivated transaction.
Jonathan P. and Margaret A. Wolff
Increased Interest
Year Deficiency Sec. 6621(c)
1979 $55,114 *
1980 82,369 *
1981 2,294 *
* Briefs amicus curiae were filed by Joel E. Miller as
attorney for Allan D.Yasnyi, Martin B. Boorstein, and Marilyn G.
Boorstein, and by Eli Blumenfeld as attorney for Lesley Yasnyi,
other partners against whom respondent has determined income tax
deficiencies relating to the same issue involved herein. These
other partners have filed petitions in this Court, and they have
filed stipulations to be bound by the final resolution of the
instant cases.
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