John G. Goettee, Jr. and Marian Goettee - Page 10

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               On September 22, 1986, Shematz notified petitioners that               
          respondent intended to seek continuances in the Bromwell cases              
          pending resolution of Leger v. Commissioner, supra, and that the            
          decision in Leger v. Commissioner, supra, was likely to be                  
          appealed and would thus delay the outcome of their case for                 
          several years.                                                              
               On March 18, 1987, we filed our opinion in Leger v.                    
          Commissioner, T.C. Memo. 1987-146, affd. without published                  
          opinion 860 F.2d 435 (5th Cir. 1988), wherein we sustained the              
          Commissioner’s determinations that the taxpayers were not                   
          entitled to claim their distributive share of the partnership               
          investment credit and losses, because the partnership was not               
          engaged in for-profit activities under section 183.                         
               On May 15, 1987, petitioners’ case was assigned to Special             
          Trial Judge Pate for trial or other disposition.                            
               On March 20, 1989, Special Trial Judge Pate invited Winkler            
          and the Barrister cases taxpayers or their counsel (including               
          petitioners’ case) to a pretrial conference scheduled for June              
          16, 1989, in order to consider and decide a number of procedural            
          matters, including “The choice of lead cases (a maximum of                  
               Winkler determined that, if the Tax Court was going to try a           
          Barrister case, then the Commissioner and the taxpayers should              
          follow the Tax Court’s opinion, rather than the Commissioner’s              

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