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failure to abate the balance of the interest was an abuse of
discretion.
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.
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-
6233.
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