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5. The Taxpayers are not entitled to any
deductions in the taxable year ending December 31,
1981, or in any subsequent year, other than the
deductions which are set forth in paragraphs “1”
and “2” above.
6. Any release, discharge or forgiveness of
any obligation with respect to the Taxpayers’
investment in the Partnership in any year
subsequent to the taxable year ending December 31,
1981 will not result in gross income to the
Taxpayers in any taxable year.
7. No penalty shall be assessed against the
Taxpayers for the taxable year ended December 31,
1981 or any subsequent taxable year by reason of
the disallowance of any losses claimed as a result
of their interest in the Partnership. The
increased interest rate pursuant to I.R.C. �
6621(c) shall apply.
This agreement is final and conclusive except:
(1) the matter it relates to may be reopened in
the event of fraud, malfeasance, or
misrepresentation of material fact;
(2) it is subject to the Internal Revenue Code
sections that expressly provide that effect
be given to their provisions notwithstanding
any other law or rule of law except Code
section 7122; and
(3) if it relates to a tax period ending after
the date of this agreement, it is subject to
any law, enacted after the agreement date,
that applies to that tax period.
By signing, the above parties certify that they
have read and agreed to the terms of this document.
Respondent accepted the closing agreement on October 13, 1988.
Respondent made adjustments to petitioner and Mr. Hopkins’s
1982 and 1983 returns pursuant to the closing agreement. Those
adjustments resulted in deficiencies for 1982 and 1983, which
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