Jerry and Patricia A. Dixon, et al. - Page 58

                                       - 21 -                                         

          as home mortgage interest that was probably attributable to the             
          Bauspar program.  On August 13, 1985, the Thompsons filed a pro             
          se petition in this Court seeking a redetermination of the                  
          asserted deficiency, additions, and increased interest for                  
          1981.12                                                                     
          The Thompsons thus had three of their taxable years before                  
          the Court in three docketed cases.  Respondent’s determinations             
          of the Thompsons’ Federal income tax deficiencies and additions             
          for their taxable years 1979-1981 were as follows:                          
                   Additions to tax                                                   
          Sec.      Sec.       Sec.        Sec.                                       
          Year    Deficiency  6651(a)   6653(a)   6653(a)(1)  6653(a)(2)              
          1979     $18,161     ---       $908       ---         ---                   
          1980      24,838     ---        ---   ---     ---                           
          1981      36,295    $4,934      ---       $1,958   50% of the               
                    interest due                                                      
                                                             on the                   
                                                             deficiency               
          Total   79,294     4,934      908        1,958     ---                      
          Respondent also determined that the Thompsons were liable for               
          increased interest for 1981 pursuant to section 6621(c).                    
               On November 21, 1985, the Chief Judge of this Court assigned           
          all the Kersting project cases to Judge William A. Goffe (Judge             
          Goffe) for trial or other disposition.  Subsequent Kersting                 
          project cases were automatically assigned to Judge Goffe.                   


          12The Thompsons apparently filed their petition for their                   
          1981 taxable year pro se, even after Seery had entered his                  
          appearance in the earlier cases.                                            




Page:  Previous  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  Next

Last modified: May 25, 2011