- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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