Robert W. Ackerman and Patricia A. Ackerman - Page 8

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          "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 a                




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