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