-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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011