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Held: The Court lacks jurisdiction to review P’s
claim for relief under sec. 6015(c), I.R.C., because,
in the context of the TEFRA partnership proceeding, P’s
claim for relief from joint and several liability on a
joint return may be raised only after R has sent a
notice of computational adjustment following the
completion of partnership-level proceedings.
John Mark Colvin, for petitioner.
Thomas D. Greenaway, for respondent.
OPINION
COHEN, Judge: This case is before us on respondent’s motion
to dismiss for lack of jurisdiction on the ground the notice of
deficiency is invalid and prohibited by section 6225. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the year in issue.
Background
The parties stipulated certain facts solely for our action
on respondent’s motion to dismiss for lack of jurisdiction.
Peter D. Adkison (petitioner) resided in Seattle, Washington, at
the time that he filed his petition.
Petitioner filed a joint Federal income tax return for 1999
with his spouse, Cathleen S. Adkison. The Adkisons claimed
deductions and losses on their 1999 tax return in connection with
their participation in a partnership known as Shavano Strategic
Investment Fund, LLC (Shavano). Shavano engaged in a tax shelter
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Last modified: November 10, 2007