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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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