- 11 - settlement involves allowing investors to deduct theft losses incurred as a result of their dealings with Hardin. Willner receives no benefit from the settlement. On October 4, 1995, Willner filed a Motion for Leave to File Notice of Election to Participate in order to contend that he was not a partner in the partnership that is the subject of this proceeding, and on January 11, 1996, he filed his jurisdictional motion. Discussion "[M]ushrooming administrative problems experienced by the Internal Revenue Service in auditing returns of partnerships, particularly tax shelter partnerships with numerous partners", led to the enactment of the TEFRA partnership proceedings in 1982. Boyd v. Commissioner, 101 T.C. 365, 368 (1993). The purpose of the new procedures was to provide a method for uniformly adjusting items of partnership income, loss, deduction, or credit, without the necessity of separate proceedings for each partner. Id. at 369; Maxwell v. Commissioner, 87 T.C. 783, 787 (1986). Willner here seeks to avoid the normal consequences of our determination in this action, which would be an assessment against him based on disallowance of all partnership losses claimed by him on his 1986 return under the name and EIN of Oceanic Leasing. See secs. 6225, 6229(d) and (e), 6231(a)(6); Sente Inv. Club Partnership v. Commissioner, 95 T.C. 243, 248-249Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011