The Manchester Group and Subsidiaries, Formerly Torrey Enterprises, Inc., and Subsidiaries, Formerly Torrey Development Corporation and Subsidiaries - Page 4

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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           
               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               
               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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