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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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