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the Barrister Equipment Associates Series 162 limited partnership
(Series 162); (2) whether petitioners are liable for the
additions to tax for negligence under sections 6653(a) and
6653(a)(1) and (2); (3) whether petitioners are liable for the
additions to tax for valuation overstatements under section
6659(a); (4) whether petitioners are liable for the additions to
tax for substantial understatements of income tax under section
6661(a) for the taxable years 1983 and 1984; and (5) whether
petitioners are liable for the increased rate of interest under
section 6621(c) for each of the years at issue.
These issues arise from petitioner's investment as a limited
partner in Series 162. During 1983 and 1984, Series 162's
principal place of business was in Rockville Centre, New York.
Series 162 was one of approximately 95 limited partnerships
organized in 1983 and 1984 that have been referred to as the
Barrister Equipment Associates partnerships (the Barrister
partnerships). This case is part of a national litigation
project initiated by respondent involving the Barrister
partnerships. The facts of this case are very similar to those
considered by this Court in Barrister Equipment Associates Series
#115 v. Commissioner, T.C. Memo. 1994-205. The facts in this
case are also essentially the same as those considered in In re
MDL-731-Tax Refund Litigation v. United States, 989 F.2d 1290 (2d
Cir. 1993). Accordingly, in this case, the Court will summarize
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