-23- certain issues by respondent on brief, Rule 155 computations will be necessary in these cases.15 The parties settled several issues in these cases before and during the trial. In addition, the parties’ objections and responses to the STJ report narrowed the issues remaining in dispute. The issues left to be decided are: (1) Whether payments received by various entities associated with Kanter during the years at issue represent income earned by and properly taxable to Kanter, Ballard, and Lisle; (2) if the Court sustains respondent’s determinations that Kanter, Ballard, and Lisle are taxable on the payments in question, whether Kanter and Ballard are liable for additions to tax for fraud; 15 In several of the cases in which respondent filed amended pleadings seeking increased deficiencies in tax and additions to tax, respondent left blank the amounts of additional income as to which increased deficiencies were asserted, with footnotes stating that such “amounts will be provided later”. Petitioners filed motions to strike respondent’s assertions of increased deficiencies where the amounts of increased income or disallowed expenses were not specifically asserted. The Court denied petitioners’ motions but ordered respondent to file amended pleadings by a designated date asserting the amounts of increased income or disallowed expenses. Respondent filed amended pleadings to comply with the Court’s order in all pertinent cases except two: Docket Nos. 31301-87 and 33557-87, Burton W. and Naomi R. Kanter. An order will be issued on the Court’s own motion in docket No. 31301-87 striking respondent’s assertion of increased income to the Kanters from IRA for the 1978 tax year. No such order will be issued in docket No. 33557- 87 because the transaction as to which respondent asserted increased income is an issue the parties have identified as Cablevision Programming Investments, which the parties have settled.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011