- 4 - Respondent also determined in the notice that petitioners were liable for additional interest under section 6621(c) by virtue of a substantial underpayment of tax attributable to a tax-motivated transaction. The deficiency in income was essentially attributable to respondent's determination that petitioners derived substantial gain in a complex transaction involving the disposition of an indirect interest in an office building. In September 1992, petitioners filed a timely petition contesting respondent's determinations. At the same time, petitioners designated San Diego, California, as the place of trial. The petition was subscribed by J. Clancy Wilson, the attorney who has continued to represent petitioners throughout these proceedings. Petitioners' counsel was formerly an attorney for the Tax Division of the U.S. Department of Justice. He is also certified by the State of California as a specialist in taxation law and is an experienced tax litigator. In November 1992, an answer was filed by respondent's District Counsel Office in San Diego. Shortly thereafter, in December 1992, the case was referred to respondent's Appeals Office in San Diego for settlement consideration. Because of the amounts in controversy and the complexity of the issues, the case was assigned to a senior Appeals officer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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