Robert C. Olson - Page 3

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          section 6223(c)(1), respondent mailed the NBAP to petitioner at             
          the address set forth on Schedule K-1 of the partnership return.            
               On March 23, 1988, and pursuant to section 6223(a)(2),                 
          respondent mailed a notice of final partnership administrative              
          adjustment (FPAA) to Computer Graphics' tax matters partner (TMP)           
          regarding the partnership's 1982 taxable year.  Approximately one           
          month later, on April 18, 1988, and pursuant to section                     
          6223(a)(2) and (d)(2), respondent mailed a copy of the FPAA to              
          petitioner.                                                                 
               The FPAA that was sent to petitioner was mailed to him at              
          1445 E. Irish Lane, Littleton, Colorado 80122 (the Irish Lane               
          address).  Petitioner resided at the Irish Lane address on April            
          18, 1988, and continued to reside there at least through                    
          September 26, 1995.                                                         
               In August 1988, a petition for readjustment of partnership             
          items was filed in response to the FPAA that respondent had                 
          previously issued in respect of Computer Graphics' 1982 taxable             
          year.  The petition, which was assigned docket No. 21062-88, was            
          filed by a partner other than petitioner, and it served to                  
          commence a partnership level proceeding (the partnership                    
          proceeding).                                                                
               In September 1992, respondent filed a motion to dismiss for            
          failure to properly prosecute and a motion for appointment of tax           
          matters partner in the partnership proceeding.  Subsequently, in            





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