[DOWNLOAD] "Smith V. Commissioner Of Internal Revenue" by United States Court Of Appeals For The Sixth Circuit # eBook PDF Kindle ePub Free
eBook details
- Title: Smith V. Commissioner Of Internal Revenue
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 27, 1991
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 80 KB
Description
Appellants, Dean B. Smith and Irma Smith, appeal from the decision of the United States Tax Court concerning deficiencies and penalties imposed upon their federal income tax for 1981 and 1982 by the Commissioner of Internal Revenue. The Tax Court determined that the 1981 and 1982 deficiencies constituted substantial underpayments attributed to a tax-motivated transaction under I.R.C. § 6621 and that petitioners were liable for an additional assessment (in addition to § 6661). Smith v. Commissioner, 91 T.C. 733 (1988). On this appeal, we must decide: (1) whether the Tax Court correctly determined the taxpayers were not entitled to deduct their allocable shares of partnership losses from the Koppelman Process activities; and (2) whether the Tax Court correctly sustained an addition to petitioners' tax under I.R.C. § 6661 for a substantial understatement of tax and imposed additional interest under § 6621(c) for substantial underpayments attributable to tax-motivated transactions.