Crest v. United States

MEMORANDUM DECISION

TASHIMA, District Judge.

This is an income tax refund suit to recover deficiencies assessed by the Internal Revenue Service (“IRS”) for the years 1976, 1977 and 1978. Plaintiffs Crest and Reeder1 are partners in several Income Real Estate Partnerships (“IREP”), each of which owns and operates a residential apartment complex in the Tacoma, Washington area. On their respective tax returns, each plaintiff reported his allowable share of partnership income and depreciation deductions from each IREP. The IRS determined that plaintiffs had calculated incorrectly the amount of the…