- 2 -
BEGHE, Judge: In Richards v. Commissioner, T.C. Memo. 1997-
149, the Court denied petitioners' Motion for Leave To File
Motion To Vacate Decision. This matter is now before the Court
on petitioners' Motion for Reconsideration and attached Motion To
Consolidate.
Background2
1. Petitioners' Case
On or about June 25, 1979, Benness M. Richards and Jane
Richards filed a joint Federal income tax return for 1978
reporting adjusted gross income of $86,574, taxable income of
$11,975, and tax due of $3,495. In computing their taxable
income, petitioners claimed an interest deduction attributable to
their participation in certain programs managed by Henry
Kersting. Because petitioners' 1978 tax return is not part of
the record in this case, we are unable to determine the specific
amount of the Kersting-related interest deduction that
petitioners claimed on their return.
On January 22, 1981, following an undercover investigation,
the Internal Revenue Service (IRS) searched Mr. Kersting's
offices pursuant to a search warrant issued by the U.S. District
Court for the District of Hawaii. Among the materials seized
during the search were lists identifying, by name and address,
2 Although the background of this case is set forth in
Richards v. Commissioner, T.C. Memo. 1997-149, for the sake of
completeness and convenience we will repeat the background here.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011