- 5 - the claimed Partnership losses is a substantial underpayment attributable to tax motivated transactions under Internal Revenue Code sec. 6621(c). Accordingly, the annual rate of interest payable on the taxpayer’s income tax for the taxable years 1983, 1984 and 1985 shall be 120 percent of the adjusted rate established under Internal Revenue Code sec. 6621(b). The 120 percent interest rate applies to interest accruing after December 31, 1984. (6) The taxpayer is not liable for any additions to tax pursuant to I.R.C. secs. 6653(a)(1), 6653(a)(2), or 6661(a) for the portion of the taxpayer’s deficiencies which are based on the disallowances of the Partnership’s losses and credits in any taxable years. (7) The taxpayer is not liable for any other penalties or additions to tax in any taxable year with respect to its interest. On March 28, 2000, the IRS mailed a letter with enclosures to the Beagles explaining how the adjustments that were made during the examination of Wilshire West affected their individual tax returns for 1983 and 1984. On June 5, 2000, the IRS assessed a deficiency of $4,432.53 for 1983 and $269.14 for 1984 against the Beagles, resulting from the adjustments made to Wilshire West that passed through to Jackson and then to the Beagles. The deficiencies resulted from disallowance of losses claimed by the Beagles from Jackson in excess of $2,500. The $2,500 amount was allowed as a deduction in 1983 equal to one-half of the Beagles’ cash investment. On May 28, 2000, the Beagles requested abatement of the interest of $22,770.39 that had accrued on their tax liability for 1983 and 1984. At that time, Robert Beagles was terminallyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011