- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011