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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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