Frances L. and Gary L. Rambacher - Page 11

          petitioners' investment.  See, e.g., Heasley v. Commissioner, 902           
          F.2d 380 (5th Cir. 1990), revg. T.C. Memo. 1988-408.                        
               In addition, petitioners argue that they acted in good faith           
          and disclosed sufficient information on their return, and                   
          therefore no additions should apply under section 6653(a).                  
          Petitioners rely on Belz Investment Co. v. Commissioner, 72 T.C.            
          1209 (1979), affd. 661 F.2d 76 (6th Cir. 1981); Wesley Heat                 
          Treating Co. v. Commissioner, 30 T.C. 10 (1958), affd. 267 F.2d             
          853 (7th Cir. 1959); Pullman, Inc. v. Commissioner, 8 T.C. 292              
          (1947); and Cryder v. Commissioner, T.C. Memo. 1977-103.                    
          Petitioner's reliance is misplaced.                                         
               Petitioners did not provide sufficient information to                  
          apprise respondent of their position on their return.  In fact,             
          there is no reference on petitioners' return to the Barrister               
          partnerships in respect of petitioners' claimed ITC.  We do not             
          believe that the mere listing of tax identification numbers of              
          the partnerships on Schedule E of their 1983 return constitutes             
          sufficient information to apprise respondent that there was any             
          issue with petitioners' treatment of the ITC.                               
               Finally, petitioners argue that respondent has forced                  
          petitioners to petition this Court in an attempt to discern the             
          basis for the deficiencies asserted against them.  Petitioner's             
          argument seems to be that respondent should be equitably estopped           
          from assessing the deficiencies.                                            

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