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bound by the settlement entered into between Nurseries' TMP and
the Commissioner, and they have failed to bring an appropriate
and timely section 6230 proceeding.
We sympathize with petitioners, but must point out that
petitioners are not victims of respondent or the Internal Revenue
Code. They are victims of unscrupulous purveyors of tax shelters
who, having sold scam investments to petitioners, failed to
follow procedures and disappeared with the funds. Petitioners
are also victims of their own greed and naivete by investing in
these scams, obtaining outrageous deductions and credits without
paying attention to the details of the tax laws, nor putting into
place some sort of check and balance system to monitor their own
investments.
Respondent's motion to dismiss will be granted, and all
references to Nurseries in the petition will be stricken.
An appropriate order
will be issued.
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Last modified: May 25, 2011