Robert C. Olson - Page 2

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          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.                                                                      
               In 1982, petitioner was a partner with a 1.2374-percent                
          interest in a partnership known as Computer Graphics Partners,              
          Ltd. Pacific (Computer Graphics).  On his income tax return for             
          1982, petitioner deducted his distributive share of the loss                
          claimed by Computer Graphics on its partnership return for that             
          year.                                                                       
               Computer Graphics was formed after September 3, 1982.                  
          Accordingly, the examination of Computer Graphics' 1982 taxable             
          year was required to be made, and was in fact made, pursuant to             
          the unified partnership audit and litigation procedures set forth           
          in sections 6221 through 6231.1  Tax Equity and Fiscal                      
          Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),            
          96 Stat. 324, 648.                                                          
               The Partnership Proceeding                                             
               In January 1985, and pursuant to section 6223(a)(1),                   
          respondent mailed petitioner a notice of beginning of                       
          administrative proceeding (NBAP) regarding the examination of               
          Computer Graphics' partnership return for 1982.  Pursuant to                



          1 Unless otherwise indicated, all section, subchapter, and                  
          chapter references in this Opinion are to the Internal Revenue              
          Code, as amended.                                                           




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