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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
DINAN, Special Trial Judge: Respondent determined that
petitioners are not entitled to an abatement of interest on
Federal income taxes for the period January 1, 1992, through
November 5, 1998, relating to their 1983 through 1986 and 1988
through 1991 taxable years. The only issue for decision is
whether respondent abused his discretion in failing to abate the
assessment of interest.
Background
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. On the date the petition
was filed in this case, petitioners resided in Vero Beach,
Florida, and neither petitioner had an individual net worth
exceeding $2 million.
In the years 1983 through 1985, petitioners invested a total
of $150,000 in a limited partnership known as Green Leasing
Associates. Green Leasing was organized and marketed by Kent
Klineman or an affiliated entity and by CIGNA Securities, a
division of Connecticut General Life Insurance Co. Green Leasing
was one of four partnerships which made up another partnership
known as Madison Leasing. These partnerships had over 100
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