- 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