Thomas Frederick Dadian and Lois Ann Dadian - Page 16

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        partnership as late as September 9, 1995.  Deverna v.                         
        Commissioner, T.C. Memo. 2004-80.  In Deverna, we recognized that             
        because there were many Swanton investors, 2 years from the time              
        of settlement was an acceptable delay.  Nevertheless, to prepare              
        closing agreements, Ms. Sullivan was ultimately just taking                   
        numbers from records that were available to her.  The South Bay               
        closing agreement was sent to Redwood in February or March 1996.              
        Respondent has not adequately explained the additional 6-month                
        delay in sending out South Bay’s closing agreement.  Ms.                      
        Sullivan’s only explanation of the delay was that the Swanton                 
        investors were numerous.  Without a more specific explanation of              
        the events that caused the additional 6-month delay past the time             
        the closing agreements were sent out in Deverna, abatement of                 
        interest is appropriate for this additional 6-month period.                   
        Therefore, it was an abuse of discretion to deny abatement of                 
        interest for the period September 9, 1995, through March 31, 1996.            
        D.  April 1, 1996, Through March 31, 1998                                     
             Ms. Sullivan sent the closing agreements to Redwood by March             
        31, 1996.  Sometime at the end of 1997, Redwood’s TMP informed Ms.            
        Sullivan that the computations she had done for Redwood were based            
        on incorrect investment figures.  Ms. Sullivan testified that she             
        based her calculations on records that the Swanton Corp. kept for             
        all the Swanton programs.  Redwood’s investment schedule differed             
        from those of the other Swanton programs.  The Swanton records do             






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