- 5 - terms that would allow the investors an ordinary loss deduction for the amount of cash invested in the partnerships. For partnerships formed in 1979 and 1980, respondent’s offer of settlement expired on September 5, 1986. By that date, petitioners did not respond to respondent’s offer of settlement. On December 27, 1988, petitioners mailed to respondent 10 checks totaling $130,836. On each check, petitioners indicated whether the amount of each check should be applied to taxes or to interest owed for each year. No indication appeared on the checks as to whether the payments were being made in settlement of all or any portion of the tax liabilities determined by respondent against petitioners, nor did any indication appear on the checks as to whether the payments were being made for any tax liabilities relating to White Rim or to Syn-Fuel, or both. Over the course of 1989 through 1997, petitioners and their counsel and respondent exchanged various correspondence and other documents discussing petitioners’ tax liabilities and that petitioners on December 27, 1988, had partially paid. The correspondence makes clear that, except as noted below, no settlement was entered into by petitioners and respondent for any of the tax years in dispute herein. For example, included in the documents petitioners submitted to respondent are claims for refund that petitioners filed in 1990 and in 1994 seeking refunds from respondent of amountsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011