Benness M. Richards and Jane Richards - Page 5

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          adjustments.5  Disputing the $67,972.50 figure used in the notice           
          of deficiency, the petition includes an allegation that the                 
          interest deduction reported on petitioners' 1978 income tax                 
          return attributable to their participation in Kersting programs             
          was only $38,523.6  In addition, the petition includes an                   
          allegation that the notice of deficiency issued to petitioners is           
          arbitrary and capricious.                                                   
               On September 13, 1982, respondent filed an answer to the               
          petition.  Specifically, respondent denied for lack of sufficient           
          information the allegation respecting the specific amount of the            
          interest deduction reported on petitioners' 1978 tax return and             
          denied without qualification the allegation that the notice of              
          deficiency is arbitrary and capricious.                                     
               On January 27, 1987, Luis C. DeCastro, Esq. (Mr. DeCastro),            
          filed an entry of appearance on behalf of petitioners in docket             
          No. 17445-82.  In the interim, on December 23, 1986, respondent's           
          counsel assigned to the Kersting project, Kenneth McWade, Esq.              
          (Mr. McWade), had mailed Mr. DeCastro a letter enclosing proposed           
          decision documents for petitioners and several of his other                 
          clients with cases before the Court involving Kersting-related              


          5  Petitioners resided in Woodland Hills, California, at the                
          time the petition was filed.                                                
          6  The petition identifies the payees as Atlas Funding                      
          Corp., Fargo Acceptance Corp., Federated Finance Co., Forbes                
          Acceptance Corp., and Mahalo Acceptance Corp.                               




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