John G. Goettee, Jr. and Marian Goettee - Page 1

                                 T.C. Memo. 2003-43                                   

                               UNITED STATES TAX COURT                                

               JOHN G. GOETTEE, JR. AND MARIAN GOETTEE, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 26591-96.             Filed February 25, 2003.              

                    Ps claimed investment credits and losses arising                  
               out of a partnership in which they held a limited                      
               interest.  By notice of deficiency, R disallowed these                 
               claimed credits and losses.  R extended a uniform                      
               settlement offer to all taxpayers, including Ps,                       
               involved in similar partnerships.  Ps promptly                         
               communicated to R their acceptance of the offer, but R                 
               did not send to Ps a proposed decision document for                    
               about 11 months.  When Ps received this document, they                 
               promptly executed and returned it to R, but R did not                  
               sign it for about 5 months.  After entry of decision, R                
               assessed (1) the deficiencies and additions as                         
               determined in the decision document, plus interest                     
               thereon, and (2) accrued, but unassessed interest on                   
               previously assessed deficiencies.  Ps paid the                         
               deficiencies and additions, and requested an abatement                 
               of interest.  R initially disallowed Ps abatement                      
               request in full; Ps appealed.  On appeal, R issued a                   
               notice of determination allowing a partial abatement.                  
               Ps then paid the remaining assessed interest                           

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