- 9 -
particular year does not foreclose the assessment of additional
taxes for that year. Dorl v. Commissioner, 507 F.2d 406 (2d Cir.
1974), affg. T.C. Memo. 1973-145.
Based on the record, we hold that petitioners have failed to
carry their burden of proving that the TEFRA settlement
agreements for partnership years 1982, 1983, and 1984 also
effected settlement of the deficiencies determined with respect
to petitioners' 1978, 1979, 1981, and 1982 returns relating to
the Carrington Equipment Associates 1981 partnership year.
To reflect our conclusion with respect to the only disputed
issue and the concessions made by the parties,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011