- 4 - 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 returnsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011