Alice M. Beagles - Page 10

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          partnership proceeding notices from the IRS).  The failure to               
          give such notices, therefore, is not an error requiring abatement           
          of interest.                                                                
               Although it may provide no comfort to petitioner, the delays           
          experienced in processing her case were not unusual during the              
          period from 1984 to 1992.  A large number of tax shelter cases              
          were filed in this Court during the late 1970s and early 1980s as           
          a result of tax shelter programs such as those promoted by                  
          Swanton.  The large number of cases led to specialized responses            
          by the IRS, by the Court, and by Congress.  The response of                 
          Congress included the increased rate of interest accruing under             
          former section 6621(c) applicable to deficiencies attributable to           
          tax-motivated transactions, as explained in H. Rept. 98-861, at             
          985-986 (1984), 1984-3 C.B. (Vol. 2) 239-240:                               
                    The provision is effective with respect to                        
               interest accruing after December 31, 1984, regardless                  
               of the date the return was filed.                                      
                    The conferees note that a number of the provisions                
               of recent legislation have been designed, in whole or                  
               in part, to deal with the Tax Court backlog.  Examples                 
               of these provisions are the increased damages                          
               assessable for instituting or maintaining Tax Court                    
               proceedings primarily for delay or that are frivolous                  
               or groundless (sec. 6673), the adjustment of interest                  
               rates (sec. 6621), the valuation overstatement and                     
               substantial understatement penalties (secs. 6659 and                   
               6661), and the tax straddle rules (secs. 1092 and                      
               1256).  * * *                                                          
                    The conferees believe that, with this amendment,                  
               the Congress has given the Tax Court sufficient tools                  
               to manage its docket, and that the responsibility for                  
               effectively managing that docket and reducing the                      

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