T.C. Memo. 2004-13
UNITED STATES TAX COURT
CHARLES G. AND ELIZABETH A. FARGO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9492-02L. Filed January 16, 2004.
Dennis N. Brager, for petitioners.
Linette B. Angelastro, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: The petitioners, Charles and Elizabeth
Fargo, bought two tax shelters 20 years ago. When respondent
disallowed their losses and sent them a notice of deficiency in
2000, time and the compounding of interest had nearly quadrupled
their total bill. Petitioners paid the tax portion of the
deficiencies in full. We consider whether respondent abused his
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