2
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011