- 2 -
and 66591 in the respective amounts of $5,564 and $33,383 due
from petitioner for the taxable year 1981. Respondent also
determined an addition to tax under section 6653(a)(2) in the
amount of 50 percent of the interest due on a deficiency in the
amount of $111,277 and that the increased interest provisions of
section 6621(c) applied.
After a concession by respondent regarding the
inapplicability of the additions to tax regarding petitioner’s
investment in Greenfield Arbitrage Partners, the sole issue
before the Court at this time is whether petitioner is foreclosed
from litigating the items contained in the notice of deficiency
regarding Resource Reclamation Associates (RRA) by a closing
agreement that he and respondent executed pursuant to section
7122. Petitioner resided in New York, New York, at the time the
petition was filed.
Background
The relevant facts may be summarized as follows. On his
1981 Federal income tax return petitioner claimed, inter alia,
ordinary losses from his limited partnership interest in Resource
Reclamation Associates (RRA) and Greenfield Arbitrage Partners
(Greenfield) in the respective amounts of $41,074 and $74,972.
Petitioner further reported $424,106 of property qualifying for
1 Section references are to the Internal Revenue Code in
effect for the year in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011