Alice M. Beagles - Page 2

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          failure to abate the balance of the interest was an abuse of                
               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              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Pacific Palisades, California, at the time            
          that she filed her petition.                                                
               During 1983 and 1984, petitioner and her husband Robert                
          Beagles (the Beagles) were limited partners in Jackson &                    
          Associates (Jackson).  The Beagles purchased their limited                  
          partnership interest in Jackson for $5,000 in 1983.  Jackson was            
          a limited partner in Wilshire West Associates (Wilshire West)               
          during 1983 and 1984.  Wilshire West was one of approximately 50            
          coal programs that were sponsored by Swanton Corp., a Delaware              
          corporation, and were structured identically as either joint                
          ventures or limited partnerships.  Both Jackson and Wilshire West           
          were partnerships subject to the procedures of the Tax Equity &             
          Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324             
          (TEFRA), provisions found in Internal Revenue Code sections 6221-           

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