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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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Last modified: May 25, 2011