Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 40

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             year thereafter.  Finally, section 6229(f) provides that,                
             if one or more of the events described in section 6231(b)                
             take place, under which partnership items are converted                  
             into nonpartnership items, and if the event takes place                  
             before the expiration of the period of limitations on                    
             assessment, then the period of limitations with respect to               
             the tax on those items will not expire before 1 year after               
             the conversion.                                                          
                  In substance, petitioners argue that their petition                 
             for readjustment must be dismissed and respondent must be                
             foreclosed from assessing any tax attributable to the                    
             subject partnership items on two grounds.  As mentioned                  
             earlier, the first ground is that respondent failed to mail              
             the notice of FPAA to the tax matters partner.  We have                  
             disposed of that contention above.  The second ground is                 
             that respondent failed to give petitioners the notice                    
             required by section 6223(a)(2) within the time required by               
             section 6223(d)(2), with the result that their partnership               
             items for 1983 became nonpartnership items, pursuant to the              
             remedy provision set out in section 6223(e), and cannot be               
             adjusted in this proceeding at the partnership level.                    
                  In support of their second ground, petitioners assert               
             that the notice of FPAA was never mailed to the notice                   
             partners as required by section 6223(a)(2).  In further                  






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