Meserve Drilling Partners, Regional Resources, Inc., F.K.A. R&R Energy, Inc., Tax Matters Partner - Page 3

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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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