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MEMORANDUM OPINION
SWIFT, Judge: These consolidated cases are before us on
motions for entry of decisions.2 An evidentiary hearing was held
on December 9, 1999, with regard to these motions.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The underlying tax liabilities involved in the instant
motions for entry of decisions of Thomas J. and Ann M. Fisher
(who are petitioners in docket No. 27394-86 and who are
hereinafter referred to as petitioners) relate to two tax shelter
limited partnerships (the White Rim partnerships and the Syn-Fuel
partnerships) in which petitioners in the early 1980's invested.
Both of these tax shelters and the claimed tax benefits
associated therewith have been the subject of test case opinions
adverse to the investors. See Peat Oil & Gas Associates v.
Commissioner, 100 T.C. 271 (1993) (relating to the Syn-Fuel
2 In docket No. 27394-86, petitioners Thomas J. and Ann M.
Fisher move for entry of decision. In docket Nos. 5879-89,
25436-90, and 1321-92, respondent moves for entry of decisions
under Rule 248, to which motions the Fishers, as participating
partners, object. Also, in the latter three dockets, the
Fishers, as participating partners, cross move, as to themselves
only (not as to other partners) for entry of decisions, for
abatement of interest, for innocent spouse relief, and for
attorney’s fees. In those three dockets, the tax matters partner
filed no response to the pending motions.
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