claim that we lack jurisdiction over the portions of the
deficiency determinations with respect to Westco Transportation
Co. (Westco) and Makalu Apartments, Ltd. (Makalu), partnerships
of which petitioner John W. Schwartz (petitioner) is a partner,
because respondent failed to comply with the Tax Equity and
Fiscal Responsibility Act (TEFRA) provisions of section 6223(a).
Respondent objects to the motions on the grounds that Westco and
Makalu fall within the small partnership exception to the
partnership audit and litigation provisions, and, therefore,
TEFRA procedures do not apply. A hearing was held with respect
to these motions in St. Louis, Missouri.
At the time the petitions were filed herein, petitioners
resided in Creve Coeur, Missouri. On June 5, 1992, respondent
mailed a notice of deficiency to petitioners for taxable years
1987, 1988, and 1989. On January 19, 1993, respondent issued a
second notice of deficiency to petitioners for taxable years 1985
and 1986. The deficiencies in and additions to petitioners' 1985
through 1989 taxes, as determined by respondent, are attributable
in part to petitioner's interests in several partnerships and S
corporations. The entities identified in the notices of
deficiency are D & J Transportation, Inc. (D&J), J & J Marine,
Inc. (J&J), MMM Management Corporation (MMM), Westco, and Makalu.
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