Thomas Corson - Page 1

                                   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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