- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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