T.C. Memo. 1996-299
UNITED STATES TAX COURT
CASCADE PARTNERSHIP, JAMES M. AND MARGARET C. COSTELLO,
TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18078-90. Filed June 26, 1996.
Larry N. Johnson, for petitioner.
Edward D. Fickess, for respondent.
MEMORANDUM OPINION
GERBER, Judge: The parties, by means of cross-motions for
partial summary judgment, seek resolution of their controversy
over whether the period for assessment had expired at the time
respondent mailed the Notice of Final Partnership Administrative
Adjustment (FPAA). More specifically, the question we consider
is whether a consent (to extend the period for assessment)
executed by one of the partnership’s general partners,
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011