2
year 1981 in the amount of $128 under section 6653(a)(1) and for
50 percent of the interest due on the underpayment of income tax
assessed in the amount of $2,564, pursuant to section 6653(a)(2),
attributable to adjustments in the underlying partnership
proceedings which resulted in automatic adjustments to
petitioners' income pursuant to the provisions of the Tax Equity
& Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96
Stat. 324.
The issue for decision is whether petitioners are liable for
additions to tax for negligence or intentional disregard of rules
or regulations. Petitioners concede that the statute of
limitations does not bar an assessment with respect to 1981.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Ironton, Ohio, at the time that they filed their petition.
References to petitioner are to Gary L. Rambacher.
In 1982 petitioner received a solicitation to purchase an
interest in a limited partnership, Barrister Equipment Associates
Series Ninety Eight (Series 98). Petitioner received a private
placement memorandum and offering summary for Series 98.
Petitioner received a private placement memorandum and offering
summary for Barrister Equipment Associates Series 124 (Series
124) as well. Petitioner contacted Robert Gold, a general
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011