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the taxable years 1983, 1984, and 1985. Ira N. Smith, the tax
matters partner for December Associates, invoked this Court's
jurisdiction by filing separate petitions for readjustment. See
December Associates, Ira N. Smith, Tax Matters Partner v.
Commissioner, docket Nos. 25083-89, 25087-89, and 16800-90.
On March 16, 1994, this Court entered decisions in each of
the foregoing 3 dockets involving December Associates. The
decisions eliminated all income, deductions, and credits claimed
on December Associates' partnership returns for 1983, 1984, and
1985. No appeals were taken, and the decisions became final on
June 14, 1994. Secs. 7481(a), 7483.
Shortly thereafter, respondent made computational
adjustments to petitioner's tax liability for 1983, 1984, and
1985 in order to reflect the disallowance of the losses that
petitioner had claimed from his investment in December
Associates. Sec. 6231(a)(6). Specifically, respondent computed
petitioner's tax liability based upon the elimination of
petitioner's distributive share of the December Associates'
losses that petitioner reported in 1983, 1984, and 1985, as well
as the elimination of the related net operating losses (NOL's)
that petitioner carried forward from 1983 to 1984 and from 1984
to 1985. Consistent with these computations, and within 1 year
of June 14, 1994, respondent assessed petitioner $9,284 in
additional tax for 1984 and $1,399 in additional tax for 1985.
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