Jesse M. and Lura L. Lewis - Page 5

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          under section 6653(a)(1)(B) for 1986.5  For 1984, respondent also           
          determined an addition to tax of $880.75 under section 6661 for             
          substantial understatement of tax.                                          
               Petitioners, originally proceeding pro se, filed a petition            
          in this Court on June 2, 1987, seeking a redetermination of the             
          deficiency, additions to tax, and additional interest determined            
          by respondent for the year 1983.  On July 18, 1988, petitioners             
          filed a similar petition with respect to their 1984 taxable year,           
          and on November 14, 1988, they filed their petition with respect            
          to their 1986 taxable year.  When petitioners filed their                   
          petitions, they resided in Westlake Village, California.                    
               The Kersting Project                                                   
               The deficiencies, additions to tax, and interest stemmed               
          from petitioners’ participation in tax shelter programs promoted            
          by Henry F.K. Kersting (Mr. Kersting).  Respondent issued the               
          notices of deficiency to petitioners in furtherance of a project,           
          called the Kersting project, that respondent had established                
          regarding those programs.  Respondent also sent notices of                  
          deficiency to other taxpayers who had participated in the                   
          Kersting programs.  Ultimately, more than 1,800 cases arising               
          from disallowance of deductions claimed by participants in the              


               5Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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