Hyman S. and Gaile S. Zfass - Page 6

                                         -6-                                          
               The partnership was one of 27 partnerships for which there was         
          a test case, Charlton v. Commissioner, T.C. Memo. 1990-402, affd.           
          990 F.2d 1161 (9th Cir. 1993).  Like the partnership in which               
          petitioner was involved, the three partnerships at issue in                 
          Charlton invested in the production of videotapes for use in                
          continuing medical education programs.  In Charlton, we held that:          
          (1) The three partnerships lacked the requisite profit objective;           
          (2) the sales forecast and the values of the license, leases, and           
          tapes were grossly overstated; and (3) these were sham transactions         
          entered into primarily for their tax benefits.  We therein upheld           
          the additions to tax for negligence and substantial understatement          
          of tax and imposed additional interest attributable to a tax-               
          motivated transaction.                                                      
               Following Charlton, on January 25, 1993, the partnership’s tax         
          matters partner and the IRS entered into a stipulated decision in           
          which the tax matters partner agreed to the disallowance of all             
          deductions and investment tax credits.  Thereafter, petitioners             
          were assessed $15,773 for 1982 and $10,805 for 1983; they concede           
          liability for those assessments.  At issue herein are the resulting         
          additions to tax for negligence under section 6653(a)(1) and (2)            
          and the additions to tax for valuation overstatement under section          
          6659.2                                                                      

               2    Petitioners request that we consider whether they are             
          liable for additional interest under sec. 6621(c).  Because the             
                                                             (continued...)           





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