- 4 - Background A complete copy of the statutory notice of deficiency is not a part of the record in this case. Based upon the pleadings, we find that the deficiencies, additions to tax, and the increased rate of interest on underpayments of tax due to tax motivated transactions result from deductions and credits taken by petitioners as flow-through items from the 1981 partnership year of "Carrington Equipment Associates".4 Petitioners argue that the issues in the present case were settled and the taxes paid under prior agreements with the Internal Revenue Service (IRS). Respondent's answer to petitioners' argument is that any prior settlements with petitioners covered matters other than those raised by the notice of deficiency in this case. The parties submitted as evidence at trial copies of 3 Forms 870-L(AD), "Settlement Agreement For Partnership Adjustments And Affected Items". Each agreement is signed by petitioners and dated January 2, 1990. The three settlement agreements relate to: (a) "Barrister Equipment Associates, Series 83", for partnership tax year 1982; (b) "Carrington Equipment Associates" 4Paragraph 4(a) of the petition alleges that "All investment tax credits were disallowed on Carrington Equipment Associates" and should have been allowed. Paragraph 5 of the petition alleges, and respondent admits in her answer that "It is our information that this case is being tried under a test case on the 1981 partnership of Carrington Equipment Associates".Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011