Charles Deverna - Page 4

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          On October 26, 1990, Brown filed a petition in response to the              
          FPAA, and the case was docketed in the Tax Court at docket No.              
          24099-90.                                                                   
          Settlement Negotiations                                                     
               In September 1991, while waiting for the decisions of the              
          Court in the earlier test cases, the legal representatives of the           
          20 TEFRA partnerships reached a basis for settlement with the               
          IRS.  The parties agreed to general settlement terms which then             
          had to be applied individually to each of the 20 TEFRA                      
          partnerships and then to each limited partner within each                   
          partnership.  The general basis of settlement, in part, was as              
          follows:                                                                    
                    (a) taxpayers would be entitled to deduct 1/2 of                  
               the out of pocket cash paid to the partnership in the                  
               year the cash was paid;                                                
                    (b) the Internal Revenue Service agreed to waive                  
               any penalties asserted in the FPAA; and                                
                    (c) the I.R.C. section 6621(c) rate of interest                   
               would apply to any deficiency.                                         
               The basis of the settlement for all of the TEFRA                       
          partnerships was the same.  For the IRS to credit nearly 1,000              
          limited partners in the TEFRA partnerships with the proper                  
          settlement, individual computations were necessary first at the             
          partnership level.  Each of the TEFRA partnership’s tax returns             
          was different from the other partnerships’ returns, and each of             
          the limited partner’s deductions on their individual tax returns            






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