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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