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Petitioner Mrs. Fisher’s claims for innocent spouse relief
for 1983 and later years and petitioners’ claims for abatement of
interest and for attorney’s fees are all premature and therefore
will be denied. Any innocent spouse relief available to
Mrs. Fisher relating to partnership items under the Tax Equity
and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat.
324 (such as the White Rim and Syn-Fuel investments for 1983,
1984, and 1985), would be governed by the separate and
independent proceedings described in section 6230(a)(3).
Any abatement of interest that might be available to
petitioners would be governed by the separate proceedings
described in section 6404(e). See Bourekis v. Commissioner,
110 T.C. 20, 26 (1998).
In light of our denial of petitioners’ motions for entry of
decisions, petitioners do not qualify as prevailing parties, and
we deny petitioners’ motions for attorney’s fees. See sec. 7430.
To reflect the foregoing,
An appropriate order will
be issued in docket No. 27394-86;
and orders and decisions will be
entered in docket Nos. 5879-89,
25436-90, and 1321-92.
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