Charles Deverna - Page 2

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          October 12, 1993, and September or October 1998 was an abuse of discretion. 
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Garden City, New York, at the time the                
          petition in this case was filed.                                            
               During 1982 through 1984, petitioner was an investor in                
          Manhattan Associates, a coal mining partnership.  Petitioner’s              
          former wife, Barbara Deverna (B. Deverna), filed a joint Federal            
          tax return with petitioner.  B. Deverna was granted relief from             
          joint and several liability for the assessments resulting from              
          investments in Manhattan Associates for 1982 through 1984.                  
               Manhattan Associates was a partnership subject to the                  
          procedures of the Tax Equity & Fiscal Responsibility Act of 1982,           
          Pub. L. 97-248, 96 Stat. 324 (TEFRA), provisions found in                   
          sections 6221-6233.  Robert Brown (Brown) was the tax matters               
          partner (TMP) for Manhattan Associates.                                     
               Thirty coal mining partnerships were promoted by Norman                
          Swanton (Swanton) prior to 1982, and 20, including Manhattan                
          Associates, were formed subsequent to the effective date of TEFRA           
          (TEFRA partnerships).  Test cases involving pre-TEFRA                       






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