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
liabilities.
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