Abraham and Dina Weiss - Page 3




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          1978; and (5) whether petitioners are liable for increased                  
          interest on the deficiencies, if any, pursuant to section                   
          6621(c).                                                                    
                                  FINDINGS OF FACT2                                   
               At the time petitioners filed their petition herein, they              
          were residents of Brooklyn, New York.  During the taxable years             
          1976, 1977, and 1978, petitioner Abraham Weiss was employed as a            
          certified public accountant.  He has substantial experience in              
          preparing tax returns.  During the same years, he was also a                
          general partner in Oshtemo-Kalamazoo, a partnership involved in a           
          cable television activity.  Before he became a general partner in           
          Oshtemo-Kalamazoo, petitioner Abraham Weiss' only experience in             
          the cable television industry arose from providing accounting               
          services for clients in that industry.  He prepared the tax                 
          returns for Oshtemo-Kalamazoo for the years in issue.  At the               
          time of trial, petitioners had no documents, such as bank records           
          or other business records, relating to Oshtemo-Kalamazoo, nor               
          were they able to locate witnesses other than Mr. Weiss himself             
          who could testify regarding their investment in Oshtemo-Kalamazoo           
          and his becoming a general partner therein.                                 
               Oshtemo-Kalamazoo issued a note to acquire a cable                     
          television system in 1976.  The note was nonrecourse, and                   
          petitioners did not have personal liability on the note.                    

               2 Some of the facts have been stipulated and are so found.             
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      


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