- 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