- 7 -
contested at the individual partner level following the
completion of partnership-level proceedings. Crystal Beach Dev.
of Destin, Ltd. v. Commissioner, T.C. Memo. 2000-170. We there
explained that the part of the Taxpayer Relief Act of 1997, Pub.
L. 105-34, section 1238(a), 111 Stat. 1026, which provides that
penalties for negligence will be determined in partnership-level
proceedings applies only prospectively for taxable years ending
after August 5, 1997. Because of our lack of jurisdiction we
shall strike from the petition all references to
penalties/additions to tax.
To the extent that we have not addressed any of petitioner’s
arguments, we have considered them and find them to be without
merit.
An order will be issued
granting respondent’s motion and
dismissing those parts of the case
pertaining to claims for refund of
overpayments to shareholders of the
partnership and pertaining to the
accuracy-related penalty under
section 6662(a).
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011