123 T.C. No. 10
UNITED STATES TAX COURT
THOMAS CORSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1025-03. Filed August 11, 2004.
P was an investor in a partnership involved in tax
shelter litigation in this Court. In 1985, P entered
into settlement agreements with R, pursuant to which P
could not deduct losses in excess of payments he had
made to or on behalf of the partnership for taxable
years before 1980 or after 1982. In 1999, after the
partnership litigation concluded, R assessed additional
income tax and accrued interest for P’s taxable year
1983 attributable to P’s involvement in the
partnership. P filed a claim for abatement of the
interest. During P’s correspondence conference with R,
P provided to R a copy of the settlement agreements and
argued that he had settled the taxable year 1983. R
refused to consider the content or effect of the
settlement agreements and denied P’s request for
abatement of interest. P then filed a petition with
this Court, appealing R’s determination. After R filed
an answer to the petition, R decided that P was
entitled to a full abatement of interest for the
taxable year 1983. P then filed a motion with this
Court for reasonable litigation costs.
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