Oceanic Leasing, Douglas F. Spaulding, Tax Matters Partner - Page 10

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          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          dismiss was withdrawn as a result of a settlement reached between           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).  The                  




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