- 3 -
were claimed as a result of the unfortunate decision to
participate in a purported tax shelter in late 1982 to offset
dividend income petitioners received from a family-owned
corporation.
Respondent determined the following additions to tax for
petitioners’ 1979, 1980, 1981, and 1982 tax years:
Year Sec. 6659 Sec. 6653(a)(1) Sec. 6653(a)(2)
1979 $2,895.60 $482.60 1
1980 6,239.40 1,039.90 1
1981 2,724.60 454.10 2
1982 14,412.90 2,404.75 2
1 Respondent conceded the additional 50 percent interest.
2 50 percent additional interest
The partnership in question is subject to the provisions of the
Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.
97-248, 96 Stat. 324, and the treatment of partnership items was
determined at the partnership level. The underlying deficiencies
in income tax have been previously determined based upon the
TEFRA partnership case Madison Recycling Associates v.
Commissioner, T.C. Memo. 2001-85, affd. 295 F.3d 280 (2d Cir.
2002).
The parties agree that any request for relief from joint and
several liability under section 6015 by petitioner wife should
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