W. Robert Curtis and Cheryl L. Riess-Curtis - Page 5

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          1989 to the Curtis-Hamada partnership.3  The FPAA determined that           
          the income and losses from the Curtis-Hamada partnership should             
          be allocated equally between the Hamada corporation and the                 
          Curtis corporation as indicated on the Schedules K-1 as                     
          originally filed.  On September 18, 1995, a petition was filed              
          with the Court in respect of the FPAA.  That petition is styled             
          "Curtis, Hamada & Curtis, Curtis & Riess-Curtis, P.C., Tax                  
          Matters Partner", docket No. 18481-95 and is presently pending              
          before the Court.                                                           
               In August 1995, respondent disclosed to petitioners that the           
          notice of deficiency with respect to petitioners' individual                
          income tax return was untimely mailed because the time prescribed           
          by section 6501(a) for assessing any additional income tax in               
          respect of petitioners' 1989 taxable year had expired before                
          petitioners agreed to extend the time for assessment.  On this              
          basis respondent proposed a settlement to petitioners that would            
          eliminate the entire deficiency in income tax and additions to              
          tax for 1989.                                                               
               On August 31, 1995, the Court entered a decision in this               
          case pursuant to the agreement of the parties.  The decision                
          reflected the parties' agreement that petitioners were not liable           
          for any deficiency in income tax or additions to tax for the                
          taxable year 1989.                                                          

          3 The FPAA identified the Curtis corporation as the tax                     
          matters partner for the Curtis-Hamada partnership.                          

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