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petition application, for a review of Failure to Abate Interest”,
which the Court filed on February 10, 2005, as “Amendment to
Petition”; (3) a letter dated March 19, 2005, entitled “Amended
Petition for Review of Failure to Abate Interest Under Code
Section 6404"; and (4) a one paragraph “Notice of Objection” to
respondent’s motion.
Relevant facts that do not appear to be in dispute are
reflected in the pleadings, respondent’s motion, the affidavit of
respondent’s counsel, and the exhibits attached thereto. For
additional background information (since it relates to this
case), reference is made to our Memorandum Opinion in Alhouse v.
Commissioner, T.C. Memo. 1991-652, affd. sub nom. Bergford v.
Commissioner, 12 F.3d 166 (9th Cir. 1993). In the absence of a
comprehensive statement of facts to support respondent’s motion,
the facts contained in the following summary are gleaned from the
above sources, and also from settlement documents filed at
Crystal Star Eagle v. Commissioner, docket No. 16434-96 (Dec. 7,
2001), which also relates to this case.
Petitioners were investors in an entity called Crystal Star
Eagle in 1985 and 1986. The entity’s investors were advised by
the promoters that they would have the legal status of tenants in
common, which permitted the direct deduction of entity items such
as certain losses, as well as depreciation, interest, and
management expenses, attributable to the entity’s activities.
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