- 2 - 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. Background 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 1988. On February 5, 1991, respondent mailed to decedent a notice of the beginning of an administrative proceeding (NBAP) 1(...continued) amended. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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