- 14 - 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 stipulatedPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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