John G. Goettee, Jr. and Marian Goettee - Page 8

                                        - 8 -                                         
          6621(c) (hereinafter sometimes referred to as the section 6621(c)           
               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.                   
               Secs. 6653(a), 6659, and 6621(c) were repealed by sec. 7721            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

Last modified: May 25, 2011