- 2 -2
The issues for decision are:
1. Whether respondent’s denial of petitioners' claim for
abatement of interest that accrued after 19872 for petitioners'
1979 and 1982 tax years was an abuse of discretion. We hold that
it was not except as noted herein.
2. Whether we have jurisdiction to review respondent's
failure to abate additional interest for tax-motivated
transactions imposed by section 6621(c) as in effect for the
years in issue. We hold that we do not.
Unless otherwise indicated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure. References to petitioner are to
David Kincaid.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners lived in Yuma, Arizona, when they filed the
petition to abate interest.
A. Petitioners’ Investment in Signature Associates
In the early 1980's, petitioners invested in Signature
Associates (Signature), a limited partnership, which invested in
1(...continued)
Restructuring and Reform Act of 1998, Pub. L. 105-206, secs.
3305(a), 3309(a), 112 Stat. 685, 743, 745.
2 Petitioners do not request abatement of interest that
accrued before Jan. 1, 1988.
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