Daniel C. Greer and Winnie L. Greer - Page 1

                                 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                  
                    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