Ralph Howell - Page 2




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          failing to abate assessments of interest relating to petitioner’s           
          1984, 1985, and 1986 taxable years.1                                        
                                     Background                                       
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulation of facts and the attached exhibits are           
          incorporated herein by this reference.  At the time he filed his            
          petition, petitioner resided in Florida.                                    
          I.  AMCOR Partnership Proceedings                                           
               Petitioner invested in separate tax shelter partnerships               
          sponsored and operated by Amcor Capital, Inc. (AMCOR), in each of           
          the years 1984, 1985, and 1986.  Petitioner filed a Form 1040,              
          U.S. Individual Income Tax Return, for each of the 3 years,                 
          reporting substantial losses attributable to his AMCOR                      
          partnership investments in each year.2  Respondent accepted                 
          petitioner’s 1984, 1985, and 1986 returns as filed.                         
               During the 1980s and 1990s, respondent pursued extensive               
          civil and criminal investigations into the operation of AMCOR and           




               1  All section references are to the Internal Revenue Code             
          in effect for the years in issue unless otherwise indicated, and            
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               2  After receiving an extension of time to file, petitioner            
          timely filed his 1984 return.  Petitioner filed his 1985 and 1986           
          returns a few days after the end of extension periods respondent            
          granted.                                                                    






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