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Additions to Tax
Petitioners Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
The Harlans $548,186 $27,409 1 $137,047
The Ockels 62,490 3,125 2 15,623
1 50 percent of interest due on $548,186.
2 50 percent of interest due on $62,490.
The instant cases have been severed from docket Nos. 15653-
92 and 15654-923 for briefing and opinion on the 2d-tier
partnership issue.
The 2d-tier partnership issue has been submitted fully
stipulated; the stipulations and the stipulated exhibits are
incorporated herein by this reference.
Background
When the respective petitions in the instant cases were
filed, the Harlans resided in Hillsborough, California, and the
Ockels resided in Lafayette, California.
3Cases of the following petitioners had originally been
consolidated: (1) Alan B. Steiner and Barbara W. Steiner, docket
No. 28182-92; (2) Estate of James Beaton, deceased, Shirley
Beaton, Executrix, and Shirley Beaton, docket No. 28181-92; (3)
James F. Ottinger and Bonnie J. Ottinger, docket No. 15654-92;
(4) Theodore S. Ockels and Rosemarie G. Ockels, docket No. 24609-
92; (5) Ridge L. Harlan and Marjory C. Harlan, docket No. 21214-
92; and (6) Estate of William H. Abildgaard, deceased, William
Abildgaard, Jr., Executor, and Marlene Abildgaard, docket No.
15653-92. See Steiner v. Commissioner, T.C. Memo. 1995-122. The
Beaton, docket No. 28181-92, and Steiner, docket No. 28182-92,
cases were severed from the group and were disposed of on another
issue. See Beaton v. Commissioner, T.C. Memo. 1997-140.
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Last modified: May 25, 2011