D. Jean Bartelma and Dan F. Bartelma - Page 2

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          claims to abate interest on income tax liabilities for 1995                 
          pursuant to section 6404(e).  The issue for decision is whether             
          the failure to abate the additional interest was an abuse of                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue.                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioners resided in Runnells, Iowa, at the time that they                
          filed their petitions in these cases.                                       
               Dan F. Bartelma (Dan) and James Richard Bartelma (James)               
          were equal general partners in Bartelma Farm Partnership (the               
          partnership).  They were also shareholders, along with other                
          family members, in Bartelma Farms, Inc.  The partnership timely             
          filed its Form 1065, U.S. Partnership Return of Income, for 1995.           
          Petitioners timely filed their individual income tax returns for            
               On May 9, 1997, petitioners were notified that the                     
          partnership’s Form 1065 for 1995 was assigned for examination.              
          Petitioners met with an agent of the Internal Revenue Service               
          (IRS), Matthew M. McKenney (McKenney), on May 27, 1997, and                 
          received the examination results in a letter dated July 14, 1997.           
          The examination resulted in adjustments to the partnership’s                

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