Estate of Jack L. Bradley, Deceased, John S. Bradley, Successor Executor, C.T.A. - Page 14

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          final partnership administrative adjustment (the FPAA) to the               
          partnership for the tax years 1985 and 1986 on December 2, 1991.            
          On March 2, 1992, the partnership filed a petition with this                
          Court challenging the correctness of the FPAA, but making no                
          claim that it was not timely.  That case was captioned Hambrose             
          Leasing 1984-5 Limited Partnership, Barry M. Goldwater, Jr., Tax            
          Matters Partner v. Commissioner, under docket number 4539-92, and           
          we will hereinafter refer to it as Hambrose II.                             
               On September 1, 1992, this Court issued its opinion in a               
          related case, pertaining to the 1984 tax year, Hambrose Leasing             
          v. Commissioner, 99 T.C. 298 (1992), which we hereinafter refer             
          to as Hambrose I.  In Hambrose I, we held that the issue of                 
          whether a partner is at risk under section 465 must be decided in           
          a partner-level proceeding, not in a partnership-level                      
          proceeding.  In that opinion, we also decided that, for purposes            
          of any subsequent litigation involving the partnership, the                 
          installment note for the additional equipment was nonrecourse as            
          to the partnership.  Id. at 303, 312.  The decision in that case            
          was entered on September 24, 1992, and became final on December             
          23, 1992.                                                                   
               On October 6, 1993, this Court granted respondent's motion             
          in Hambrose II to dismiss for lack of jurisdiction with respect             
          to the at-risk issue under section 465, and all references to               
          this issue were stricken from the pleadings.  On May 27, 1994, we           
          entered a decision in Hambrose II based on a stipulated                     




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