- 2 - 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 100Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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