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$102,856. Respondent further determined that the Dixons were
liable for negligence additions for 1977 through 1980 under
section 6653(a) and for 1981 under section 6653(a)(1). The
deficiencies and negligence additions so determined were
attributable to their participation in Kersting tax shelter
programs.
The test case petitioners also included John R. and Maydee
Thompson (the Thompsons) and Mr. and Mrs. John R. Cravens (the
Cravenses).7 The Thompsons’ deficiencies were for the taxable
years 1979 through 1981 and totaled $79,293. Respondent further
determined that the Thompsons were liable for additions to tax
for negligence for 1979 and 1981 and for increased interest for
1981 pursuant to section 6621(d),8 as well as a late filing
addition to tax for 1981 under section 6651(a). The
deficiencies, negligence additions, and increased interest were
attributable to their participation in Kersting tax shelter
programs. The Thompsons filed a petition in this Court seeking
review of the deficiencies, increased interest, and additions,
with Mr. Seery as their counsel.
7Mr. Seery particularly wished to include the Cravenses as
test case petitioners because they treated their payments to Mr.
Kersting to participate in the programs as basis reductions that
resulted in their reporting capital gains on terminating their
interests in the programs.
8Sec. 6621(d) was redesignated sec. 6621(c) by the Tax
Reform Act of 1986 (TRA), Pub. L. 99-514, sec. 1511(c)(1)(A)-(C),
100 Stat. 2744. We will hereinafter refer to the provision as
sec. 6621(c).
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