- 2 - respondent’s denial of petitioners’ claim for abatement of interest that accrued from December 31, 1988, through August 1997 for petitioners’ 1982 and 1983 taxable years was an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts is incorporated herein by this reference. Petitioners resided in Woodbury, New York, when they filed their petition in this case. They filed joint individual income tax returns for 1982 and 1983. During 1982 and 1983, Mr. Leffert was a certified public accountant, and Mrs. Leffert was a teacher. Mr. Leffert’s Investment in Blue Gem Associates In or about 1982, Mr. Leffert invested in 7201 Associates, a general partnership that acquired a limited partnership interest in Blue Gem Associates (Blue Gem), a coal mining limited partnership that was subject to the unified audit and litigation provisions of the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. 1(...continued) Revenue Service Restructuring & Reform Act of 1998, Pub. L. 105- 206, secs. 3305(a), 3309(a), 112 Stat. 685, 743, 745. 2Unless otherwise indicated, all section references are to the Internal Revenue Code as amended. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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