- 5 - additional tax liability for petitioner. The adjustments contained in the 1982 FPAA did. On August 4, 1988, a petition for readjustment of partnership items was filed by another partner of Elite (who was not the tax matters partner), contesting respondent's adjustments to Elite's 1982, 1983, and 1984 taxable years. Petitioner did not join in this action, and he never filed an objection on his own behalf. On January 16, 1991, a decision was entered by this Court in Elite's case with respect to its 1982, 1983, and 1984 taxable years. In accordance with a stipulation of the parties there, the decision stated that Elite had no basis in its partnership assets for purposes of depreciation and energy credits. Respondent later assessed each of Elite's partners additional tax on account of computational adjustments. Respondent mailed an affected items notice of deficiency to petitioner, asserting that he was liable for additions to his 1982 tax on account of his investment in Elite. On May 26, 1992, petitioner petitioned this Court with respect to this notice. In essence, petitioner attacks the notice's validity on the ground that respondent failed to provide him with proper notice of Elite's proceeding. According to petitioner, respondent failed to follow established international mailing procedures when she mailed him the 1982 FPAA. Section 912.42 of the Domestic MailPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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