William L. and Mary Lee Powell - Page 2

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          involves the scope of the Court's jurisdiction in an affected-              
          items proceeding.                                                           
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated by this reference.  Petitioners resided in Dallas,             
          Texas, at the time their petition was filed.                                
               In 1982 petitioners invested $12,500 in the partnership                
          Barrister Equipment Associates Series 112 (Barrister Series 112),           
          through their investment in an S corporation known as Erath                 
          Enterprises, Inc. (Erath).                                                  
               On November 17, 1989, respondent issued separate notices of            
          final partnership administrative adjustment (FPAA) to the tax               
          matters partner (TMP) of Barrister Series 112 for the taxable               
          years 1982 and 1983.  The adjustments were the subject of                   
          proceedings at the partnership level pursuant to sections 6221              
          through 6233.  This Court entered a stipulated decision in the              
          partnership proceeding, Anderson Equip. Associates v.                       
          Commissioner, docket No. 27745-89, on February 17, 1995.                    
          Pursuant to section 7481, that decision became final on May 18,             
          1995.                                                                       
               On March 25, 1996, respondent made an assessment of a                  
          computational adjustment against petitioners for 1983 resulting             
          from the partnership adjustments and an assessment for interest,            
          including additional interest under section 6621(c).  On April              






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