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certify this case for immediate appeal if we do not grant his
motion.
Respondent determined that petitioner had an income tax
deficiency of $369,390 for 1987 and was liable for additions to
tax for 1987 of $92,348 for failure to timely file under section
6651(a)(1) and $92,348 for substantial understatement of tax
under section 6661.
A hearing was held on petitioner's motion in Winston-Salem,
North Carolina.
We must decide the following issues:
1. Whether respondent's deficiency determination is valid
for jurisdictional purposes. We hold that it is.
2. Whether it is appropriate in this case to certify
denial of petitioner's motion for interlocutory appeal. We hold
that it is not.
Section references are to the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
A. Petitioner
Petitioner lived in Asheville, North Carolina, when he filed
the petition in this case. In 1985, 1986, and 1987, petitioner
lived in Europe. He owned several businesses that sold resort
time shares. He was a director of A.T.O. Marketing Limited
(A.T.O.) in 1987. A.T.O., an Isle of Man entity, sued Kenning
Atlantic Iberica, NV (Kenning), a former partner. The case was
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