- 6 - a combination of withheld taxes ($1,868), estimated tax payments ($17,000), and other refundable credits ($500). On June 13, 1983, respondent refunded to petitioners $14,851.79, consisting of $14,549 plus interest thereon (for the period Apr. 15 through June 1, 1983) in the amount of $302.79 for 1982. A. The Transaction On the recommendation of John’s father, an accountant and tax attorney, John3 acquired a limited partnership interest in The Thompson Equipment Associates partnership (hereinafter sometimes referred to as TEA) during September 1981. John acquired the interest in TEA in exchange for a $12,500 check and a $12,500 promissory note which matured on February 15, 1982. Marian issued a check on February 10, 1982, that paid the promissory note in full. Petitioners claimed flowthrough losses from TEA on their tax returns for 1981, 1982, and 1983. Petitioners carried back “credits/losses” from 1981 to 1978 and 1979. As a result of the “credits/losses” carried back from 1981 to 1979, on June 28, 1982, respondent refunded to petitioners $10,375.38, consisting of $9,568 plus interest thereon (for the period Jan. 1 through 3 The parties have stipulated that (1) John acquired the partnership interest, and (2) both petitioners were limited partners. The parties have not reconciled the two stipulations. It does not appear to matter to the instant case whether Marian also was a limited partner in Thompson Equipment Associates. For convenience, we refer to John as the limited partner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011