Deborah K. Skyrms - Page 6

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               Petitioner's investment in Republic represents almost 40               
          percent of her reported taxable income for 1982.  She did not               
          have an attorney or accountant examine the investment.                      
          Petitioner relied on Russell's verbal explanation of the                    
          partnership and did not read the offering memorandum.  Russell              
          told her that he had investigated "the partnership", and                    
          petitioner "felt" that he had thoroughly investigated the                   
          investment.                                                                 
               Although she was told in 1985 that "they were having success           
          in placing these machines," petitioner apparently took no action            
          to monitor her investment.  It was in 1985 that petitioner last             
          spoke to Russell who filed for bankruptcy under Chapter 7 in that           
          year.                                                                       
               In January of 1995 petitioner for the first time received              
          notice that the investment tax credits from Republic were not               
          proper.  On April 7, 1995, she paid the assessed taxes and                  
          interest due as a result of respondent's disallowance of the                
          Republic deductions and credits.                                            
               In notices of deficiency for affected items issued on                  
          February 17, 1995, respondent determined that the underpayments             
          of taxes for the years 1979 through 1982 are subject to the                 
          negligence additions of section 6653(a)(1) and (2), and that the            
          tax underpayments are attributable to a valuation overstatement             
          as described in section 6659.                                               






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