- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011