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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Secs. 6653(a), 6659, and 6621(c) were repealed by sec. 7721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.
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