Alice M. Beagles - Page 7

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          sound basis in fact or law.  Woodral v. Commissioner, 112 T.C.              
          19, 23 (1999).                                                              
               In view of the partial allowance of petitioner’s claim for             
          abatement, it is necessary to address only those periods in which           
          interest accrued between April 15, 1984, and May 8, 1992, and               
          subsequent to April 15, 1999.  An understanding of the earlier              
          period, however, requires an explanation of other events                    
          occurring during the period for which abatement was allowed by              
          the Appeals office.  The period from April 15, 1999, to                     
          September 30, 2001, is explained by the chronology in our                   
          findings of fact, and petitioner has not argued that unnecessary            
          or unexplained delay occurred during that period.                           
               Petitioner is concerned primarily by the failure of the IRS            
          to notify her and her husband of the deficiencies in tax for 1983           
          and 1984 during the time that TEFRA proceedings were pursued                
          through the TMPs of Jackson and Wilshire West.  In that regard,             
          it is necessary to understand the parameters of litigation over             
          Swanton coal shelter programs.  Much of the background was                  
          explained by the testimony of Moira Sullivan, an attorney for the           
          IRS charged with responsibility for the litigation.  Documents              
          concerning the Swanton cases were lost as a result of the                   
          destruction of the World Trade Center on September 11, 2001.                
          Other explanations are found in two opinions of this Court                  
          rendered in Swanton coal program cases.                                     

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