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partnership adjustment. Petitioner’s claim is based on his
belief that respondent should have provided him notice of the
adjustment and deficiency at an earlier date, thereby allowing
him to pay the deficiency earlier and minimize any accruing
interest. The issue for our consideration is whether respondent
abused his discretion by denying the request for abatement.
FINDINGS OF FACT
The parties’ stipulated facts and exhibits are incorporated
by this reference.
At the time his petition was filed, petitioner resided in
Dublin, California. In 1981, petitioner became a partner in
Brentwood Investors (Brentwood). While petitioner was a partner
in Brentwood, it became a partner in the Wilshire Wellesley
Associates partnership (Wilshire Wellesley), which, in turn,
became a partner in the Golden Gate Associates partnership
(Golden Gate). Brentwood had 10 partners, Wilshire Wellesley had
33, and Golden Gate had 28. Donald J. Kuehne was the tax matters
partner (TMP) of Golden Gate and of Wilshire Wellesley and the
managing general partner of Brentwood.
Respondent audited Golden Gate for the years 1982, 1983, and
1984. In connection with the 1984 audit of Golden Gate,
respondent contacted petitioner in September 1991, requesting a
copy of his 1984 Federal tax return. In October 1991,
petitioner, by letter, supplied the return and requested
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