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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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