- 10 - auditing. Among those identified by the revenue agent was Willner. A copy of the FPAA was sent to Willner. In the petition filed March 1, 1993, the adjustments in the FPAA were challenged on the following grounds: 6. The facts on which the Petitioner relies as the basis of his case are as follows: A. Not all income and expenses shown on the partnership's tax return are the result of fictitious, sham transactions; B. Some of the business activity actually occurred; and C. Property purchased by the partnership was: (a) depreciable; (b) had a useful life of at least 3 years; (c) was tangible personal property; and (d) was placed in service during the taxable year in a trade or business. 7. Petitioner further alleges that the statutory period for making an assessment for the taxable year 1986 has expired. Trial of this case commenced in San Francisco, California, in September 1994. Calef appeared by counsel and moved for dismissal of the case for lack of jurisdiction as to her, claiming that she was not a partner in the partnership that was a subject of this proceeding. The trial was thereafter continued several times for purposes of settlement discussions among various interested partners. In July 1995, Calef's motion to dismiss was withdrawn as a result of a settlement reached between herself and respondent. On August 7, 1995, respondent filed a Motion for Entry of Decision pursuant to Rule 248(b). ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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