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