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Language in Heasley v. Commissioner, supra at 386,
suggesting that profit objective, for purposes of section 6621(c)
increased interest, be evaluated at the individual investor level
is not apropos. Heasley did not involve a partnership
investment.
In light of the lack of profit objective and the lack of
economic substance associated with the activities and investments
of the Garfield and Cardinal limited partnerships, petitioners
are liable for increased interest under section 6621(c). Other
arguments made by petitioners and not addressed specifically
herein have been considered and are rejected.
For the reasons stated, respondent's imposition of increased
interest under section 6621(c) is sustained. We shall grant
respondent’s motion for partial summary judgment and deny
petitioners’ motion for partial summary judgment.
To reflect the foregoing, an
appropriate order will be issued.
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Last modified: May 25, 2011