Background Transpac Drilling Venture 1982-08 (Transpac) is a partnership subject to the unified partnership audit and litigation procedures set forth in sections 6221 through 6233. Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648. On March 23, 1990, respondent issued three separate notices of final partnership administrative adjustment (FPAA) to Transpac's tax matters partner (TMP) setting forth adjustments to Transpac's partnership items for 1982, 1983, and 1984. On April 10, 1990, respondent mailed copies of the FPAA's described above to Transpac partners Albert D. and Luella L. Eshelman (petitioners). On August 17, 1990, Charles Haydon, Esq. (Mr. Haydon) filed a timely petition for readjustment on behalf of petitioners, as partners other than the TMP, contesting the FPAA's described above.2 Sec. 6226(b). Paragraph 7 of the petition states: "The name and address of the tax matters partner, so far as known, are 2 The petition includes an allegation that Transpac's principal place of business is Scarsdale, N.Y. Respondent's answer to the petition includes a denial of this allegation for lack of sufficient information. Sec. 7482(b)(1)(E) provides that an appeal in this case will lie with the Court of Appeals for the circuit in which the partnership's principal place of business is located. Considering the limited circumstances under which this Court may vacate a final decision (as more fully discussed below), we do not find it necessary to determine Transpac's principal place of business in order to rule on the pending motion.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011