Anna Lee Locke - Page 4

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               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 income             






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