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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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