Seymour and Beatrice Leffert - Page 2




                                        - 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.                              





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