T.C. Memo. 2007-119
UNITED STATES TAX COURT
DANIEL C. GREER AND WINNIE L. GREER, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21795-03. Filed May 10, 2007.
Ps were investors in a purported tax shelter and
now dispute additions to tax related to R’s
disallowance of losses and credits resulting from the
investment.
Ps argue that they were not negligent because they
relied upon the broker selling the purported shelter
and because R did not inform Ps that the promoter of
the shelter was under investigation. Ps further argue
that the amount of underpayment used to compute the
additions to tax should be reduced to reflect the
remittance paid by Ps before filing an action in the
Federal District Court, which remittance was later
ordered by the District Court to be returned to Ps.
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Last modified: November 10, 2007