- 3 -
adjustments that had been agreed to at the Barrister partnership
level, respondent’s Appeals Offices in Fresno, California
(Fresno) and in Brooklyn, New York (Brooklyn) granted to a number
of the Barrister partners their requests under section 6404(e)(1)
for abatement of related statutory interest.
Petitioner made a similar request for abatement of interest
with regard to his Federal income tax deficiencies for 1983,
1984, and 19851 relating to the disallowed Barrister claimed
losses and credits. In his request, among other things,
petitioner alleged that his tax deficiencies relating to
Barrister were caused by erroneous advice given by a
representative of respondent to the tax matters partner of Bishop
as to the allowability of the Barrister losses and credits.
Petitioner’s request for abatement of interest was denied by
respondent.
Petitioner administratively appealed respondent’s denial of
petitioner’s request for abatement of interest. Petitioner’s
appeal was forwarded by respondent to respondent’s Appeals Office
in San Francisco, California (San Francisco). Petitioner,
however, requested that the appeal be transferred from
respondent’s San Francisco Appeals Office to either respondent’s
Fresno or Brooklyn Appeals Office in an effort to obtain the same
1 Computational adjustments for 1985 were the result of
carryforward tax credits claimed by petitioner relating to
Barrister.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011