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MESERVE DRILLING PARTNERS
Year Adjustment to Ordinary Income
1982 $1,228,560
1983 171,721
COLUMBIA ENERGY FUND 1982
Year Adjustment to Ordinary Income
1982 $3,176,180
1983 1,059,673
In the motions to dismiss, petitioner claims that the FPAA's
are invalid because they did not make determinations as to
"partnership items" on the dates they were issued and therefore
cannot confer jurisdiction on this Court. According to
petitioner's argument, the regulations defining "partnership
items" were adopted on April 15, 1986, whereas the FPAA's were
mailed on March 18, 1986. Thus, petitioner argues that because
no regulations existed when the FPAA's were mailed, pursuant to
section 6231(a)(4), all items are "nonpartnership items". In
addition, petitioner argues that the regulation defining
"partnership items" should not be used to retroactively confer
jurisdiction on this Court. Respondent asserts that the FPAA
validly confers jurisdiction on the Court and that jurisdiction
can be conferred by the retroactive application of the regulation
defining "partnership items".
Discussion
The question of jurisdiction is a fundamental question that
can be raised at any time by either party or by the Court.
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Last modified: May 25, 2011