- 3 - attributable to partnership items. See sec. 6225(a). Petitioners did not file a statement denying the settlement authority of Nurseries' TMP under section 6224(c)(3)(B) at least 30 days prior to the date on which the settlement agreement was entered into by the Commissioner and Nurseries' TMP. See section 301.6224(c)-1T(a)(2), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6786 (Mar. 5, 1987). Indeed, at that time, petitioners were unaware of the partnership proceeding. By letters dated June 14, 1993, and August 9, 1993, petitioners were advised by respondent of changes made to their 1985 and 1986 joint Federal income tax returns as a result of the settlement of the partnership items of Nurseries as they flowed through to petitioners' 1985 and 1986 returns. The computation form attached to the letter for 1985 reflected that petitioners' claimed ordinary loss of $74,978 with respect to Nurseries was disallowed except for a $25,000 settlement allowance, that a deficiency was computed in the amount of $18,429, that no additions or penalties were being asserted, but that interest was to be computed at 120 percent of the normal rates pursuant to section 6621(c). Similarly for 1986, the petitioners' claimed loss for Nurseries of $11,309 was disallowed resulting in a deficiency of $9,995. These deficiencies and appropriate interest were subsequently assessed, and petitioners began making arrangements to pay them.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011