- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011