Peter M. and Susan L. Hoffman - Page 1

                                   119 T.C. No. 7                                     

                               UNITED STATES TAX COURT                                

                    PETER M. AND SUSAN L. HOFFMAN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16028-99L.            Filed September 24, 2002.             

                    On Sept. 10, 1991, Ps timely filed a joint 1990                   
               Federal income tax return on which they reported that                  
               they:  (1) Held a general partner interest in one                      
               partnership and limited partner interests in five                      
               partnerships and (2) did not under sec. 469, I.R.C.,                   
               materially participate in any of the partnerships.                     
               On Sept. 8, 1997, Ps filed an amended return for 1990                  
               reporting additional income and remitting the tax due                  
               on that additional income.  On Nov. 6, 1997, R assessed                
               the additional tax liability reported on the amended                   
               return and assessed other amounts for a penalty and                    
               interest on that additional tax liability.                             
                    Subsequently, R issued to Ps a notice of intent to                
               levy, and Ps requested and received a hearing under                    
               sec. 6330, I.R.C.  At the hearing, Ps contended that                   
               the additional tax liability reported in 1997, the                     
               penalty, and the interest were all assessed after the                  
               expiration of the period of limitations and that they                  
               were entitled to a refund of the amount paid with the                  

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