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 the
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