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for the Seventh Circuit seeking review of some (but not all) of
the issues decided by this Court in respondent’s favor. In
Estate of Kanter v. Commissioner, 337 F.3d 833, 839 (7th Cir.
2003), the Court of Appeals listed the issues subject to review
as follows: (1) Additions to tax for fraud, (2) adjustments
related to the Bea Ritch Trusts, (3) disallowed deductions for
activities related to a painting of George Washington, (4)
unreported income for 1982 based on a bank deposits analysis, (5)
unreported income from Equitable Leasing transactions, and (6)
unreported income from a transaction related to a shelf
corporation identified as Cashmere. The Kanters also appealed
the Court’s denial of their motions to make the Couvillion report
part of the record in their cases, and Naomi R. Kanter appealed
issues related to her claims for relief under section 6015. At
the same time, Ballard appealed his cases to the Court of Appeals
for the Eleventh Circuit, and the Estate of Lisle appealed its
cases to the Court of Appeals for the Fifth Circuit.
In Ballard v. Commissioner, 321 F.3d 1037 (11th Cir. 2003),
the Court of Appeals for the Eleventh Circuit affirmed this
Court’s holdings as to Ballard in all respects.
In Estate of Kanter v. Commissioner, supra, the Court of
Appeals for the Seventh Circuit affirmed in part and reversed in
part. The Court of Appeals affirmed this Court’s holdings
denying release of the Couvillion report. The Court of Appeals
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