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signed the Form 872-A on June 10, 1986. On or before June 24,
1986, respondent countersigned the Form 872-A and returned a copy
to petitioners. The Greenfields never submitted a Form 872-T,
Notice of Termination of Special Consent to Extend the Time to
Assess Tax, to respondent for the Greenfields’ tax return.
Respondent eventually determined that the Greenfields’
distributive share of income for 1982 from the Mast Realty
Associates Partnerships should be increased by $62,186 and that
any deficiency related to the determination is subject to an
increased rate of interest under section 6621(c). On July 30,
2004, respondent mailed a notice of deficiency to the Greenfields
for 1982 reflecting the determination. Subsequently, respondent
determined that Ms. Greenfield qualified under section 6015 for
relief from any joint and several tax liability for 1982.
On September 19, 1992, Mr. Greenfield filed a petition under
chapter 11 of the Bankruptcy Code. On January 11, 1993,
respondent filed a proof of claim in Mr. Greenfield’s bankruptcy
case (first proof of claim). On October 21, 1993, Mr. Greenfield
objected to respondent’s first proof of claim, and on or about
November 9, 1993, respondent consented to the disallowance of
respondent’s first proof of claim.
Also on November 9, 1993, respondent filed a second proof of
claim in Mr. Greenfield’s bankruptcy proceeding (second proof of
claim). The second proof of claim asserted an unsecured priority
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Last modified: March 27, 2008