Charles G. and Elizabeth A. Fargo - Page 1

                                 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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