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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.
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