David E. and Jean H. Kohn - Page 2




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          Assessment and Collection.1  Respondent issued notices of                   
          deficiency for petitioners' 1979 through 1982 tax years in which            
          respondent determined additions to tax attributable to petitioner           
          David E. Kohn's partnership interest in Hamilton Recycling                  
          Associates (Hamilton).  The notices of deficiency were issued               
          following the conclusion of a partnership proceeding involving              
          Hamilton's 1982 through 1985 taxable years.  In response to the             
          notices of deficiency, petitioners have filed with this Court a             
          petition in which petitioners not only contest the additions to             
          tax, but also attempt to place in issue deficiencies that were              
          assessed by computational adjustment, additional interest that              
          was computed pursuant to section 6621(c), and the validity of the           
          underlying partnership proceedings.  All references to petitioner           
          are to David E. Kohn.  At the time of the petition petitioners              
          resided in Vadnais Heights, Minnesota.                                      
          Background                                                                  
               During 1982, petitioner became a limited partner in                    
          Hamilton.  Until February 18, 1986, Sam Winer (Winer) was                   
          Hamilton's tax matters partner (TMP).  On February 18, 1986,                
          Winer resigned as TMP pursuant to a United States District Court            
          order restricting him from representing Hamilton or its partners            

          1                                                                           
               All section references are to the Internal Revenue Code in             
          effect for the tax years in issue, unless otherwise indicated.              
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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