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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue for decision is whether petitioner is entitled to
an abatement of interest accruing on the above Federal income tax
deficiencies.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
San Francisco, California.
In 1983, petitioner purchased a limited partner interest in
Bishop Investment Group I (Bishop), which in turn invested in
Barrister Equipment Associates (Barrister), a tax-sheltered
limited partnership.
Upon audit of Barrister for 1983 and 1984, respondent
disallowed losses and credits claimed by Barrister. In Anderson
Equip. Associates, et al., Barrister Associates, Tax Matters
Partner v. Commissioner, docket No. 27745-89, respondent’s
adjustments to Barrister’s claimed losses and credits were agreed
to by the tax matters partner, and a stipulated decision was
entered consistent with that settlement.
In connection with computational adjustments that were made
by respondent at the partner level relating to the above
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