- 4 - Computer Programs Lambda, Ltd. v. Commissioner, 90 T.C. 1124, 1126 (1988), for the proposition that a viable TMP is necessary to ensure the fair, efficient, and consistent disposition of TEFRA partnership proceedings, directs the petitioners and the participating partners to select a successor TMP and notify the Court in writing, on or before June 20, 1994, of the name and address of the successor TMP. The Court did not receive a response to its order dated May 11, 1994. Accordingly, on August 19, 1994, the Court issued an order directing petitioners and the participating partners to show cause, on or before September 23, 1994, why the case should not be dismissed for failure to properly prosecute. Once again, the Court did not receive a response to its order. Consequently, on October 26, 1994, the Court entered an Order of Dismissal and Decision in which it (1) made its order to show cause dated August 19, 1994, absolute, (2) dismissed this case for failure to properly prosecute, and (3) entered a decision sustaining respondent's adjustments to Transpac's partnership items for 1982, 1983, and 1984. The Court's Order dated May 11, 1994, the Court's Order to Show Cause dated August 19, 1994, and the Court's Order of Dismissal and Decision entered October 26, 1994, were all served on Mr. Haydon as counsel of record for petitioners and thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011