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1986.1 Petitioners argue that Appeals was required to accept
their offer of $83,213 to compromise $298,003 of Federal income
tax liability that respondent’s records reported were due from
them for 1981 through 1986. We decide whether Appeals abused its
discretion in rejecting that offer.2 We hold it did not.
FINDINGS OF FACT
The parties filed with the Court stipulations of fact and
accompanying exhibits. The stipulated facts are found
accordingly. When the petition was filed, petitioners resided in
Kennewick, Washington.
Beginning in 1984, petitioners’ Federal income tax returns
claimed losses and credits from their involvement in a
partnership organized and operated by Walter J. Hoyt, III (Hoyt).
The partnership was called Shorthorn Genetic Engineering 1984-3.
Hoyt was the partnership’s general partner and tax matters
partner, and the partnership was subject to the unified audit and
litigation procedures of the Tax Equity and Fiscal Responsibility
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Dollar amounts
are rounded.
2 Petitioners also dispute respondent’s determination that
they are liable for increased interest under sec. 6621(c). This
interest relates to deficiencies attributable to “computational
adjustments”, see secs. 6230(a)(1) and 6231(a)(6), made following
the Court’s decision in Shorthorn Genetic Engg. 1982-2, Ltd. v.
Commissioner, T.C. Memo. 1996-515. As to this dispute, the
parties have agreed to be bound by a final decision in Ertz v.
Commissioner, docket No. 20336-04L, which involves a similar
issue.
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