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Beagles v. Commissioner, supra, does not provide us with
guidance for periods after May 8, 1992, because in that case the
Commissioner granted interest abatement to the taxpayer for the
period May 8, 1992, through April 15, 1999. We review the events
that occurred after May 8, 1992, to determine whether respondent
abused his discretion.
B. May 9, 1992, Through September 1993
From May 9 to August 14, 1992, respondent was involved in
litigation before this Court concerning the pre-TEFRA Swanton
programs. In accordance with our holding above, it was not an
abuse of discretion for respondent to deny interest abatement for
that period. See Lee v. Commissioner, supra.
After the completion of the pre-TEFRA Tax Court litigation,
Ms. Sullivan negotiated with counsel for the TEFRA Swanton
programs regarding the final terms of settlement until September
1993. The TEFRA Swanton settlement work was added to Ms.
Sullivan’s normal caseload. According to her testimony, because
she was not assisted by any other attorney, she could not finalize
the terms of settlement while briefing the pre-TEFRA cases. The
settlements could have been completed more quickly if more than
one person had regularly been working on them. Arguably,
respondent made a managerial error when he assigned only one
employee to handle the settlement of all of the TEFRA
partnerships. This managerial decision contributed to the delay
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