Robert C. Olson - Page 6

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          determined in the notice of deficiency, but also the                        
          computational adjustment assessed by respondent in respect of               
          petitioner's share of Computer Graphics' partnership items for              
          1982.                                                                       
               As previously indicated, respondent has filed a Motion to              
          Dismiss.  In such motion, respondent moves to dismiss for lack of           
          jurisdiction, and to strike, such portion of the petition that              
          relates to adjustments "from or to" Computer Graphics for 1982.             
          In this regard, respondent contends that the Court's jurisdiction           
          in the present case is limited to redetermining the additions to            
          tax for 1982 as determined by respondent in the affected items              
          notice of deficiency.                                                       
               Petitioner filed an objection to respondent's Motion to                
          Dismiss.  In his objection, petitioner alleged:  (1) He did not             
          receive an FPAA and was therefore not adequately notified of the            
          underlying partnership proceeding pursuant to section 6223(a);              
          (2) any FPAA mailed to him should be considered ineffective                 
          because he had health problems rendering him unable to comprehend           
          such a notice; and (3) the additions to tax determined by                   
          respondent must be assessed consistent with settlement agreements           
          previously offered by respondent to other partners of Computer              
          Graphics.                                                                   
               Respondent was directed to file a response to petitioner's             
          objections setting forth the basis upon which she relied to show            





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