- 8 - 6621(c) (hereinafter sometimes referred to as the section 6621(c) rate).4 On November 3, 1986, petitioners filed a petition with this Court seeking a redetermination of their tax liabilities for 1978, 1979, 1981, and 1982. John R. Shematz (hereinafter sometimes referred to as Shematz), who was in business with John’s father, signed the petition and initially represented petitioners in this Court. Petitioners’ case was assigned to a group of cases collectively referred to as the Barrister Books project (hereinafter sometimes referred to as Barrister). The Barrister partnerships started to be formed in 1981. Andrew M. Winkler (hereinafter sometimes referred to as Winkler) served as lead counsel for the Commissioner in the Barrister cases. Sometime around 1986, the Commissioner extended a uniform settlement offer to any Barrister investor. The Commissioner withdrew the offer on or about May 16, 1989. 4 The notice of deficiency refers to sec. 6621(d). Sec. 6621(d) was redesignated as sec. 6621(c) by sec. 1511(c)(1)((A) of the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, 100 Stat. 2085, 2744. We shall refer to this section as sec. 6621(c). Secs. 6653(a), 6659, and 6621(c) were repealed by sec. 7721 of the Omnibus Budget Reconciliation Act of 1989 (OBRA 1989), Pub. L. 101-239, 103 Stat. 2106, 2399, for tax returns due after Dec. 31, 1989. The substance of former secs. 6653(a) and 6659 now appears in sec. 6662. These repeals and revisions do not affect petitioners’ liabilities for the years involved in the notice of deficiency on which table 1 is based.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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