Martin and Barbara Schachter, (1998)
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Martin and Barbara Schachter, (1998)
T.C. Memo. 1998-260
UNITED STATES TAX COURT MARTIN AND BARBARA SCHACHTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2939-96. Filed July 15, 1998.Martin A. Schainbaum, for petitioners. Paul J. Krug, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: Respondent determined deficiencies in and additions to tax with regard to petitioners' taxable years as follows:Additions to Tax Sec. Sec. Sec. Sec. Sec. Sec. Sec.6653 6653 6653 6653 6653 6653 6653 Sec. Year Deficiency (a)(1) (a)(1)(A) (a)(1)(B) (b)(1) (b)(1)(A) (b)(1)(B) (b)(2) 66611985 $163,048 -- -- -- $81,524 -- -- ** $40,762 1986 168,368 -- $ 336 * -- $121,229 ** -- 42,092 1987 154,962 -- 2,220 * -- 82,915 ** -- 38,741 1988 21,488 $39 -- -- 15,525 -- -- -- 5,372 * 50 percent of interest due on portion of underpayment attributable to negligence.** 50 percent of interest due on portion of underpayment attributable to fraud.Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.The primary issues for decision are whether petitioners are to be charged with additional partnership income and whether petitioners are liable for the fraud and other additions to tax.FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners are husband and wife and resided in Hayward, California, at the time they filed their pe...See the full content of this document
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