- 20 -
In all of the amended answers in which respondent asserted
increased deficiencies in tax, as well as increased additions to
tax and penalties, respondent did not calculate or assert the
amounts of the increased tax deficiencies or the amounts of the
additions to tax or penalties. Respondent asserted only the
amounts of increased income or the amounts of disallowed expenses
that would result in increased deficiencies in tax and additions
to tax. As a result of these amended answers, and as a result of
numerous concessions and stipulations of settlement that were
made by the parties before, during, and after the trial, as well
as concessions of certain issues by respondent on brief, Rule 155
computations will be necessary in some of the cases.6
These cases are part of a larger group of cases that have
also been identified by respondent as a litigation project. The
sobriquet for this project is "Levenfeld/Kanter". These cases
were selected for trial because, as the Court understands, they
involve common issues that the other cases in this project do not
have.
References to Kanter, Ballard, and Lisle are to Burton W.
Kanter, Claude M. Ballard, and Robert W. Lisle, respectively.
Reference to the Kanters, Ballards, and Lisles are to Burton W.
6
In some of the cases, if petitioners are sustained on the
fraud issue, respondent will be barred by the statute of
limitations from assessment as to those petitioners.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011