Charles A. Greene and Christine J. Greene - Page 11

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               Petitioners’ reporting position, as set forth in the amended           
          return and attached Form 8082, was based on their understanding             
          of settlements purportedly entered into between respondent and              
          other Mid Continent partners for taxable years 1981 and 1982.               
               The record in this case includes the transcript of account             
          that respondent maintained for petitioners’ 1983 taxable year.              
          The transcript of account indicates that the payment of tax and             
          interest that was remitted by petitioners with their amended                
          return was posted to petitioners’ account on December 29, 1986.             
          Later, on March 9, 1987, respondent assessed $18,194 as an                  
          advance payment of an examination deficiency and $6,181.36 as a             
          designated payment of interest.                                             
               There is no evidence in the record that petitioners filed an           
          amended return for tax year 1984.                                           
          Partnership Litigation and Petitioners' Tax Assessments                     
               In October of 1990 the Court filed its opinion in Webb v.              
          Commissioner, T.C. Memo. 1990-556, remanded on a jurisdictional             
          issue 17 F.3d 398 (9th Cir. 1994), holding that the activities of           
          the partnership in 1981 and 1982 were not engaged in for profit             
          and that the underpayments of taxes resulting from the                      
          deductions, losses, and credits claimed with respect to the                 
          partnership were attributable to negligence and to tax-motivated            

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