Thomas J. Fisher and Ann M. Fisher, et al. - Page 3




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          partnerships), affd. sub nom. Ferguson v. Commissioner, 29 F.3d             
          98 (2d Cir. 1994); Krause v. Commissioner, 99 T.C. 132 (1992),              
          (relating to the White Rim partnerships), affd. sub nom.                    
          Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir. 1994).3                 
               The instant motions focus primarily on whether petitioners             
          should be treated as having entered into binding settlement                 
          agreements of the taxes and penalties pertaining to their                   
          investments in the White Rim and Syn-Fuel partnerships on a basis           
          more favorable than that available to other partners in the same            
          partnerships.  Petitioners’ counsel complains vigorously of                 
          respondent’s general handling of the above tax shelters and of              
          respondent’s particular treatment of petitioners.  Whatever may             
          be the explanation for petitioners’ financial and other problems            
          relating to their investments in the above partnerships, the                
          evidence herein does not establish that petitioners entered into            
          binding settlement agreements with respondent of their tax                  
          liabilities, additions to tax, and increased interest in a manner           
          inconsistent with respondent’s proposed decisions.  For the                 
          reasons set forth below, in docket No. 27394-86, we shall deny              

          3    For other opinions relating to the White Rim partnerships,             
          see Hill v. Commissioner, 204 F.3d 1214 (9th Cir. 2000); Copeland           
          v. Commissioner, T.C. Memo. 2000-181; Marinovich v. Commissioner,           
          T.C. Memo. 1999-179; Acierno v. Commissioner, T.C. Memo. 1997-              
          441, affd. without published opinion 185 F.3d 861 (3d Cir. 1999);           
          Karlsson v. Commissioner, T.C. Memo. 1997-432; Vanderschraaf v.             
          Commissioner, T.C. Memo. 1997-306, affd. without published                  
          opinion 211 F.3d 1276 (9th Cir. 2000).                                      






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