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obligations imposed on the TMP pursuant to Rule 248. A decision
reflecting the terms of the settlement was entered on December 7,
2001.
Petitioners’ deficiencies for 1985 and 1986 consequent to
the settlement were assessed on November 18, 2002, and December
2, 2002, respectively. Computed to the dates of assessment,
accrued interest on the 1985 deficiency totaled $6,051.89;
accrued interest on the 1986 deficiency totaled $25,137.28.
Petitioners remitted in full the underlying deficiencies for 1985
and 1986, but as of the date this case was submitted petitioners
had not paid any accrued interest.
Petitioners’ request for abatement of interest under section
6404(e), submitted on February 4, 2003, appealed to the equities
of their predicament, adducing that they remained uninformed of
the partnership action and settlement resolution throughout the
course of the proceedings, and that they were blindsided by their
liability and the extent of the attendant interest accumulation
when the assessments were ultimately effected in late 2002.
Petitioners contended that, as unsophisticated investors, they
were oblivious to the Partnership’s structure and operation and
had no forewarning that it was devised as a tax shelter vehicle.
They claimed to have been unwittingly bamboozled by
misrepresentations of the Partnership’s organizers and marketers
and duplicitous prospectus documentation. Petitioners claimed
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