Lavern Scherping - Page 3

                                        - 3 -                                         

               Following our consolidation of these cases for purposes of             
          trial, briefing, and opinion, and following our rulings granting            
          respondent's motions for partial summary adjudication, Scherping            
          v. Commissioner, T.C. Memo. 1991-384, and Scherping v.                      
          Commissioner, T.C. Memo. 1991-388, we are left to decide the                
          following issues:                                                           
               1.  Whether LaVern Scherping and Loren Scherping may deduct            
          interest expenses in amounts greater than those determined by               
          respondent.                                                                 
               2.  Whether LaVern Scherping and Loren Scherping are liable            
          for the additions to tax for negligence determined by respondent            
          under section 6653(a)(1) and (2) for 1984 and 1985 and under                
          section 6653(a)(1)(A) and (B) for 1986.                                     
               3.  Whether LaVern Scherping and Loren Scherping are liable            
          for the additions to tax for substantial understatement                     
          determined by respondent under section 6661.                                
               We hold for respondent on all issues.  Section references              
          are to the Internal Revenue Code in effect for the years in                 
          issue.  Rule references are to the Tax Court Rules of Practice              
          and Procedure.  The term "petitioners" refers to LaVern Scherping           
          and Loren Scherping collectively.                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the exhibits submitted therewith are               





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011