- 5 - 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 periodsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011