Ackerman v. Price Waterhouse

OPINION OF THE COURT

Diane A. Lebedeff, J.

This litigation springs from plaintiffs’ investments in several limited partnerships under common management, all of which involved shopping center sites and were similarly structured as tax shelters. The catalyst for the suit was a determination by the Internal Revenue Service (the IRS) that plaintiffs had claimed improperly high interest deductions. The IRS assessed plaintiffs for underpayment of taxes plus interest, computing interest at a penalty rate applicable to substantial understatements attributable to tax-motivated transactions under section…