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1989 to the Curtis-Hamada partnership.3 The FPAA determined that
the income and losses from the Curtis-Hamada partnership should
be allocated equally between the Hamada corporation and the
Curtis corporation as indicated on the Schedules K-1 as
originally filed. On September 18, 1995, a petition was filed
with the Court in respect of the FPAA. That petition is styled
"Curtis, Hamada & Curtis, Curtis & Riess-Curtis, P.C., Tax
Matters Partner", docket No. 18481-95 and is presently pending
before the Court.
In August 1995, respondent disclosed to petitioners that the
notice of deficiency with respect to petitioners' individual
income tax return was untimely mailed because the time prescribed
by section 6501(a) for assessing any additional income tax in
respect of petitioners' 1989 taxable year had expired before
petitioners agreed to extend the time for assessment. On this
basis respondent proposed a settlement to petitioners that would
eliminate the entire deficiency in income tax and additions to
tax for 1989.
On August 31, 1995, the Court entered a decision in this
case pursuant to the agreement of the parties. The decision
reflected the parties' agreement that petitioners were not liable
for any deficiency in income tax or additions to tax for the
taxable year 1989.
3 The FPAA identified the Curtis corporation as the tax
matters partner for the Curtis-Hamada partnership.
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