- 15 - 3. *Leo Fine and Judith H. Fine, Petitioners v. Commissioner of Internal Revenue, Respondent, Docket No. 35437-85 * * * * * * * * New controlling case: Harold M. Provizer and Joan Provizer, Petitioners v. Commissioner of Internal Revenue, Respondent, Docket No. 27141-86. On January 20, 1989, on behalf of SAB Foam Associates Becker submitted the following notice to respondent: In our protest dated September 28, 1988, we stated that the Partnership agreed to be bound by the lead cases (Fine, Miller and Miller). Due to various changes in circumstances including but not limited to a settlement of all such then pending lead cases, the Partnership hereby withdraws its statement to be bound by such cases or any other case. Becker mailed this notice by certified mail, return receipt requested, and signed it “Stuart Becker, Tax Matters Partner”. On December 9, 1991, respondent issued a notice of final partnership administrative adjustment (FPAA) to SAB Management for 1982. In the FPAA, respondent disallowed all items of income, losses, deductions, and credits reported with respect to SAB Foam’s equipment leasing activities for 1982. Accordingly, respondent: (1) Increased ordinary income by $662,556; (2) determined that SAB Foam’s investment and business energy tax credits with respect to the recycling equipment were zero, instead of the $7 million claimed as the qualified investment onPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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