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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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