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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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