- 23 -
Thompsons filed timely joint petitions for redetermination of the
above-described deficiencies.
C. Cravens Notices of Deficiency
John R. Cravens was a pilot with American Airlines during
1979 and 1980. Mr. Cravens became aware of Mr. Kersting's
programs through conversations with other pilots.
The Cravenses filed joint Federal income tax returns for
1979 and 1980 in which they claimed interest deductions
attributable to their participation in certain Kersting programs.
On April 15, 1983, and March 20, 1984, respondent mailed notices
of deficiency to the Cravenses determining deficiencies in and
additions to their Federal income taxes for the taxable years
1979 and 1980, as follows:
Additions to Tax
Year Deficiency Sec. 6653(a)
1979 $4,508.00 $225.40
1980 19,251.70 962.59
The notice of deficiency issued to the Cravenses for 1979, while
disallowing interest deductions of $9,810, included a credit for
personal exemptions of $4,000, resulting in a net adjustment of
$5,810. The notice of deficiency issued to the Cravenses for
1980 included disallowed interest deductions of $19,620 and, as
an alternative to the disallowance of such interest, the
inclusion of $18,000 in unreported dividend income from a
Kersting controlled entity known as Candace Acceptance Corp.
13(...continued)
provision as sec. 6621(c).
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011