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not entitled to an abatement of interest pursuant to section
6404(e)2 relating to their 1983 taxable years. Petitioners meet
the net worth limitations of section 7430(c)(4)(A)(ii).
The only issue for decision is whether respondent's refusal
to abate interest for the period of time between April 1, 1985,
and July 8, 1996, was an abuse of discretion.
Background
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations are incorporated into this
Memorandum Opinion by reference and, accordingly, are found as
facts in the instant case. When petitioner Laurence Jacobs filed
his petition, he resided in Newport Beach, California. When
petitioner Patricia Jacobs filed her petition, she resided in
Huntington Beach, California. When petitioners James and Janice
Geis filed their petition, they resided in Mission Viejo,
California.
Petitioners are limited partners in Tummies Ltd. Partnership
(TLP).3 TLP is a limited partnership subject to the provisions
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
3 Tummies Ltd. Partnership (TLP) was formed by brothers John
and William Knoke in December 1983 for the purpose of developing
a group of characters, a playboard, and an interactive record
known as the "interactor", all of which are collectively known as
the "Tummies". The partnership's promoters hoped that the
cartoon characters would be licensed for use in children's
(continued...)
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