Charles A. Greene and Christine J. Greene - Page 10

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          petitioner "became aware" that the Internal Revenue Service (IRS)           
          was disallowing deductions related to the partnership.  Corman              
          suggested that petitioner confer with a tax attorney, which he              
               On the basis of his discussions with his attorney,                     
          petitioner developed "an understanding" that other taxpayers in             
          his locale who had invested in Mid Continent were settling their            
          controversies with the IRS.  He understood that if they agreed to           
          forgo their partnership deductions, the IRS would allow Mid                 
          Continent partners to deduct their "[cash] investment", such as             
          the $10,000 payment he had made.                                            
          The Partnership Examination and Petitioners' Amended Return                 
               On August 11, 1986, respondent mailed petitioner a notice of           
          the beginning of an examination of Mid Continent’s 1983                     
          partnership return.                                                         
               On or about December 29, 1986, petitioners filed an amended            
          income tax return for 1983 (the amended return), along with a               
          Notice of Inconsistent Treatment or Amended Return on Form 8082.            
          Petitioners amended their 1983 return by reducing the $46,007               
          partnership loss with respect to Mid Continent by $36,007 and by            
          eliminating an investment tax credit in the amount of $190.                 
          Petitioners remitted a total of $24,393 with the amended return,            
          designating $18,194 as tax and $6,199 as interest.                          

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