Anna Lee Locke - Page 12

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                    (c) Period of limitations.--The period of                         
               limitations for assessment of any such liability of a                  
               transferee or a fiduciary shall be as follows:                         
                         (1) Initial transferee.--In the case of                      
                    the liability of an initial transferee,                           
                    within 1 year after the expiration of the                         
                    period of limitation for assessment against                       
                    the transferor.                                                   
               The FPAA was sent to the decedent and the tax matters                  
          partner of EXOCO on March 26, 1986.  The tax matters partner                
          filed a petition with this Court on June 20, 1986.  The decision            
          of this Court was entered pursuant to a settlement among the                
          parties to the action on April 30, 1992, and became final 90 days           
          later.  An assessment in the amount of $18,247 was made against             
          the decedent on February 15, 1993.  The statutory notice of                 
          transferee liability for the assessed amount plus interest was              
          mailed to petitioner on July 22, 1994.  The assessment is not               
          time barred, nor is petitioner's liability as transferee.                   
               Petitioner has advanced other arguments with regard to the             
          partnership item.  She contends, for example, that she was                  
          precluded by the absence of notice from negotiating a settlement            
          offered to other partners.  The assessment, however, was made               
          based on the decision entered pursuant to the settlement reached            
          in the partnership proceeding.  Other arguments related to the              
          decedent's investment in EXOCO cannot be addressed in this                  
          proceeding for reasons set forth above.                                     
          Transferee Liability                                                        






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