Larry Brown - Page 1

                                 T.C. Memo. 1997-548                                  

                               UNITED STATES TAX COURT                                

                             LARRY BROWN, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13623-96.                Filed December 11, 1997.           

                    R moved for partial summary judgment on an issue                  
               informally raised by P during an IRS Appeals Office                    
               conference as to whether the period of limitations for                 
               assessment had expired as a result of R's alleged                      
               failure to honor an election by P's partnership for                    
               treatment under the unified audit provisions of secs.                  
               6221 through 6233, I.R.C.  R also moved to impose                      
               sanctions under Rule 104(c), Tax Court Rules of                        
               Practice and Procedure, including dismissal, for P's                   
               ongoing noncompliance with a discovery order of the                    
               Court.  P filed oppositions to both of R's motions.                    
                    1.  Held:  R's motion for partial summary judgment                
               granted.  Rule 121(b), Tax Court Rules of Practice and                 

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