Thomas J. Fisher and Ann M. Fisher, et al. - Page 2




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                                 MEMORANDUM OPINION                                   
               SWIFT, Judge:  These consolidated cases are before us on               
          motions for entry of decisions.2  An evidentiary hearing was held           
          on December 9, 1999, with regard to these motions.                          
               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 underlying tax liabilities involved in the instant                 
          motions for entry of decisions of Thomas J. and Ann M. Fisher               
          (who are petitioners in docket No. 27394-86 and who are                     
          hereinafter referred to as petitioners) relate to two tax shelter           
          limited partnerships (the White Rim partnerships and the Syn-Fuel           
          partnerships) in which petitioners in the early 1980's invested.            
          Both of these tax shelters and the claimed tax benefits                     
          associated therewith have been the subject of test case opinions            
          adverse to the investors.  See Peat Oil & Gas Associates v.                 
          Commissioner, 100 T.C. 271 (1993) (relating to the Syn-Fuel                 

          2  In docket No. 27394-86, petitioners Thomas J. and Ann M.                 
          Fisher move for entry of decision.  In docket Nos. 5879-89,                 
          25436-90, and 1321-92, respondent moves for entry of decisions              
          under Rule 248, to which motions the Fishers, as participating              
          partners, object.  Also, in the latter three dockets, the                   
          Fishers, as participating partners, cross move, as to themselves            
          only (not as to other partners) for entry of decisions, for                 
          abatement of interest, for innocent spouse relief, and for                  
          attorney’s fees.  In those three dockets, the tax matters partner           
          filed no response to the pending motions.                                   






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