108 T.C. No. 1 UNITED STATES TAX COURT LAWRENCE V. AND KATHARINE T. BROOKES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11770-96. Filed January 2, 1997. Ps were partners in a partnership that was the subject of a partnership proceeding. R mailed a notice of final partnership administrative adjustment (FPAA) for taxable years 1983 and 1984 to the tax matters partner (TMP). The TMP filed a petition, and Ps filed a motion to participate in the partnership proceeding, which this Court granted. The TMP settled the partnership case and certified that no party objected to the settlement. Ps did not receive notice of the settlement before the decision was entered by this Court but received notice of the decision 4 days after it was entered. Ps object to the settlement and claim interests adverse to those of the TMP. R assessed deficiencies in Ps' Federal income taxes for 1983 and 1984 as "computational adjustments" based on the partnership adjustments. See sec. 6231(a)(6), I.R.C. Thereafter, R mailed Ps a notice of deficiency for "affected items", determining additions to tax for 1980 and 1983. Ps filed a petition for redetermination with respect to the affected items deficiency and the 1983 and 1984 assessments attributable to their share of partnership items. R filed a motion to dismiss for lack of jurisdiction and to strike the portion of thePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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