- 4 - On March 26, 1986, respondent sent a Notice of Final Partnership Administrative Adjustment (FPAA) of EXOCO partnership to Alexander Locke, M.D., at zip code 95825. The tax matters partner for EXOCO partnership filed a petition in this Court on June 20, 1986. Attached with the petition was a copy of the FPAA and a list of the investor/partners in EXOCO. The list included Alexander Locke, M.D., at zip code 95825. The tax matters partner for the EXOCO partnership and respondent subsequently entered into a settlement agreement. Pursuant to the settlement agreement, this Court entered a decision on April 30, 1992, and the decision became final 90 days later on July 28, 1992. Pursuant to the settlement and decision of this Court in the EXOCO partnership proceeding, an assessment of a computational adjustment in the amount of $18,247 was made as to the decedent on February 15, 1993. On July 22, 1994, a Statutory Notice of Transferee Liability for the assessed amount of the decedent's liability plus interest was mailed to petitioner. OPINION Respondent contends that petitioner, as transferee of the decedent, is liable for an amount equal to the decedent's 1982 income tax liability and interest. Petitioner asserts numerous and varied theories under which she claims that she is not liable as a transferee. The theories can be categorized as those that relate primarily to the incomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011