Joseph and Theresa Momot - Page 7

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          obligations imposed on the TMP pursuant to Rule 248.  A decision            
          reflecting the terms of the settlement was entered on December 7,           
          2001.                                                                       
               Petitioners’ deficiencies for 1985 and 1986 consequent to              
          the settlement were assessed on November 18, 2002, and December             
          2, 2002, respectively.  Computed to the dates of assessment,                
          accrued interest on the 1985 deficiency totaled $6,051.89;                  
          accrued interest on the 1986 deficiency totaled $25,137.28.                 
          Petitioners remitted in full the underlying deficiencies for 1985           
          and 1986, but as of the date this case was submitted petitioners            
          had not paid any accrued interest.                                          
               Petitioners’ request for abatement of interest under section           
          6404(e), submitted on February 4, 2003, appealed to the equities            
          of their predicament, adducing that they remained uninformed of             
          the partnership action and settlement resolution throughout the             
          course of the proceedings, and that they were blindsided by their           
          liability and the extent of the attendant interest accumulation             
          when the assessments were ultimately effected in late 2002.                 
          Petitioners contended that, as unsophisticated investors, they              
          were oblivious to the Partnership’s structure and operation and             
          had no forewarning that it was devised as a tax shelter vehicle.            
          They claimed to have been unwittingly bamboozled by                         
          misrepresentations of the Partnership’s organizers and marketers            
          and duplicitous prospectus documentation.  Petitioners claimed              






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