Estate of James T. Callaway, Deceased, Elizabeth N. Callaway, Executrix, and Elizabeth N. Callaway - Page 2

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               The primary issue for consideration is whether the affected            
          items notices of deficiency are valid.  In this connection, we              
          must consider whether the partnership items of each petitioner              
          converted to nonpartnership items.  If the partnership items of             
          either petitioner remain as partnership items, we must further              
          decide whether the period of limitations has expired for issuance           
          of that affected items notice of deficiency.                                
          Petitioners are the estate of James T. Callaway and                         
          Elizabeth N. Callaway (Mrs. Callaway), James T. Callaway's                  
          surviving spouse.  James T. Callaway (decedent) died on December            
          8, 1990.  Mrs. Callaway is the duly appointed executrix of                  
          decedent's estate.                                                          
               During the taxable years 1986, 1987, and 1988, decedent was            
          a limited partner in a partnership known as Mountain View Mall              
          Associates (Mountain View or the partnership).  Decedent and Mrs.           
          Callaway filed joint Federal income tax returns reporting                   
          decedent's distributive share of losses reported on Mountain                
          View's partnership returns for the taxable years 1986, 1987, and            
               On February 5, 1991, respondent mailed to decedent a notice            
          of the beginning of an administrative proceeding (NBAP)                     

          amended.  Rule references are to the Tax Court Rules of Practice            
          and Procedure.                                                              

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