Dichter v. State Tax Commission

FINDINGS OF FACT AND REPORT

The appellants, Massachusetts residents, timely filed their 1973 joint income tax return in which they reported a gain from the sale of their “participation interest” in a limited partnership. On September 13, 1976, the Commissioner of Corporations and Taxation (Commissioner) notified the appellants of his in*858tention to assess an additional tax of $11,834.73 related to that gain and resulting from the use of a different basis in the computation of the gain. After the Commissioner assessed the additional tax on December 15, 1976, with interest of $2,603.64, the…