Robert W. Ackerman and Patricia A. Ackerman - Page 5

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          for partnership tax year 1983; and (c) "Barrister Equipment                 
          Associates, Series 152", for partnership tax year 1984.                     
               As best as we can determine from the submitted documents and           
          testimony, petitioners, sometime before May of 1991, had been               
          examined and assessed additional income taxes for the years 1979,           
          1980, 1982, 1983, and 1984.  A handwritten "Record of Accounts"             
          attached to a note dated May 10, 1991, was sent to petitioners.             
          The document, prepared by an employee of respondent's Problem               
          Resolution Office, indicates the application of payments dated              
          September 12, 1990, to outstanding "audit assessments" as well as           
          unpaid interest for each of the above years.  Petitioners had               
          made a $100,000 payment by check to the IRS and received a                  
          receipt for payment of taxes dated September 12, 1990.                      
               Petitioner testified that in addition to the $100,000 paid             
          in September of 1990, he later paid about $146,000 to IRS to                
          settle "all tax years * * * germane to the Barrister case."                 
          Petitioner's testimony concerning this payment is corroborated by           
          a January 24, 1992, document prepared by a revenue officer,                 
          indicating the receipt from petitioners of 2 checks totalling               
          $146,814.78.  The document indicates that these funds were                  
          applied to "assessed penalties and interest" and "accrued                   
          penalties and interest" for the years 1979, 1980, 1982, 1983, and           
          1984.  Dr. Ackerman received a February 5, 1992, memorandum from            
          one of respondent's revenue officers stating that "All periods              




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