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1065. That amount reflects petitioners' distributive share of
the loss as allocated on the amended Schedules K-1.
On or about June 16, 1993, respondent mailed to petitioners
a notice of the beginning of an administrative proceeding (NBAP)
with respect to the partnership's 1989 taxable year. Concomitant
therewith, respondent began auditing petitioners' individual
income tax return for 1989.
On or about November 4, 1994, petitioners consented to
extend the time to assess tax with respect to their individual
income tax return for 1989.
On February 23, 1995, respondent mailed petitioners a notice
of deficiency for the taxable year 1989. In the notice of
deficiency, respondent disallowed the $35,864 loss attributable
to petitioners' interest in the Curtis-Hamada partnership.
Petitioners filed the petition in this case on May 26, 1995.
In the petition, petitioners alleged, inter alia, that the loss
attributable to petitioners' interest in the Curtis-Hamada
partnership was improperly disallowed.
On July 5, 1995, respondent filed an answer to the petition.
In the answer, respondent denied that the loss attributable to
the Curtis-Hamada partnership was improperly disallowed.
On June 16, 1995, respondent mailed a notice of final
partnership administrative adjustment (FPAA) for the taxable year
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