Duane E. Hudspath - Page 3

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          to petitioner as the tax matters partner of SCC a notice of final           
          partnership administrative adjustment (FPAA) with respect to the            
          taxable years 1996 and 1997 of SCC (SCC-FPAA).2  In the SCC-FPAA,           
          the IRS notified petitioner as the tax matters partner of SCC               
          that SCC was a sham partnership because Fair Hollow Trust, one of           
          its partners, was a sham trust and that consequently SCC was                
          invalid because petitioner was the only partner.                            
               On April 14, 2000, the IRS sent by certified mail to peti-             
          tioner as the tax matters partner of WIN an FPAA with respect to            
          the taxable years 1996 and 1997 of WIN (WIN-FPAA).  In the WIN-             
          FPAA, the IRS notified petitioner as the tax matters partner of             
          WIN that Fair Hollow Trust, one of the partners of WIN, was a               
          sham trust created by petitioner and that consequently Fair                 
          Hollow Trust’s share of the partnership items of WIN was allo-              
          cated to him.                                                               
               On April 14, 2000 (the same date on which the IRS issued the           
          respective SCC-FPAA and WIN-FPAA to Mr. Hudspath as the tax                 
          matters partner of each entity), the Commissioner sent him a                
          notice of deficiency for his taxable years 1996 and 1997 (1996              

               1(...continued)                                                        
          ning of administrative proceeding.                                          
               2The IRS mailed the SCC-FPAA to 5436 Main Street, Stephens             
          City, Virginia 22655-2829, which is the address for petitioner              
          listed in the petition in the instant case.                                 







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