- 22 - Mr. Norstrud received Mr. Nickerson's letter on June 11, 1991, and replied to it on June 13, 1991. Mr. Norstrud's reply to Mr. Nickerson is similar to the letter he sent to Mr. Denny, quoted above. It explains that a notice of FPAA had been issued and details the limitations periods for filing "a petition with the Tax Court, District Court or Court of Claims". No petition for readjustment of the partnership items that were adjusted by respondent in the notice of FPAA mailed to the tax matters partner on January 28, 1991, was filed by the tax matters partner within 90 days after January 28, 1991, nor was a petition for readjustment filed by any other partner within 150 days, after January 28, 1991. The petition for readjustment at issue in this case was not filed until April 23, 1993, 816 days after the mailing of the notice of FPAA. It was filed by five partners other than the tax matters partner. The names of those partners are set forth in the caption of this case, and they are referred to herein as petitioners. On March 7, 1994, Mr. Caldwell submitted a Notice of Election to Participate pursuant to Rule 245(b) of the Tax Court Rules of Practice and Procedure. All Rule references are to the Tax Court Rules of Practice and Procedure. By Order dated June 30, 1994, the Court granted leave andPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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