- 8 - "with respect to the determination of partnership items for any partnership taxable year." (Emphasis supplied.) The three settlement agreements in evidence are for partnership items for partnership taxable years 1982, 1983, and 1984. The partnership at issue in the agreement for 1982 is not "Carrington Equipment Associates" but "Barrister Equipment Associates, Series 83." Respondent's notice of deficiency in this case is with reference to deductions and credits claimed on petitioners' income tax returns as flow-through items from the 1981 partnership taxable year of Carrington Equipment Associates, a partnership taxable year that is not subject to the TEFRA procedures or the settlement agreements previously described. Therefore the settlement agreements relied upon by petitioner did not settle the issues that are the subject of this deficiency proceeding. Petitioners' settlement of partnership taxable items for the years 1982, 1983, and 1984 may have affected their tax liabilities for prior years due to the disallowance of loss carrybacks. But that does not prohibit respondent from making a further examination for those years for other income tax adjustments. See Digby v. Commissioner, 103 T.C. 441, 447 (1994). Further, the mere fact that a revenue officer of respondent, responsible for collecting assessed taxes, sends a letter to a taxpayer stating that he is "paid in full" for aPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011