- 44 - 1. THE ABOVE ADJUSTMENT IS THE ONLY ISSUE IN THIS CASE; 2. The above adjustment(s), as specified in the preamble, shall be determined by application of the same formula as that which resolved the same tax shelter adjustments with respect to the following taxpayer(s): Names(s): Harold M. Provizer and Joan Provizer v. Commissioner of Internal Revenue Tax Court Docket No.: 27141-86 Names(s): Elliot I. Miller v. Commissioner of Internal Revenue Tax Court Docket No.: 10382-86 Names(s): Elliot I. Miller and Myra K. Miller v. Commissioner of Internal Revenue Tax Court Docket No.: 10383-86 (hereinafter the CONTROLLING CASE) 3. All issues involving the above adjustment(s) shall be resolved as if the petitioner(s) in this case was/were the same as the taxpayer(s) in the CONTROLLING CASE; a. If the Court finds that any additions to tax or the section 6621(c) interest are applicable to the underpayment attributable to the above-designated tax shelter adjustment(s), the resolution of the tax shelter issue and the applicability of such addition to tax or interest to that tax shelter issue in the CONTROLLING CASE, whether by litigation or settlement, shall apply to petitioner(s) as if the petitioner(s) in this case was/were the same as the taxpayer(s) in the CONTROLLING CASE; 4. If the adjustment is resolved in the CONTROLLING CASE in a manner which affects the same issue in other years (e.g., * losses in later years or affects depreciation schedules), the resolution will apply to petitioners’ later years as if the petitioners in this case was/were the same as the taxpayer(s) in the CONTROLLING CASE;Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011