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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
transactions.
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