- 2 - 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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011