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respecting the partnership's 1988 taxable year. Respondent has
been unable to provide the Court with copies of the NBAP's
purportedly mailed to decedent on the same date with respect to
the partnership's 1986 and 1987 taxable years.
On December 23, 1991, Mrs. Callaway forwarded several
letters to respondent, including a request for prompt assessment
of income tax submitted on behalf of decedent's estate for the
taxable years 1983 through 1990. See sec. 6501(d). In addition,
Mrs. Callaway remitted three checks to respondent in the amounts
of $90,635, $48,846, and $8,439 designated as deposits in the
nature of a cash bond respecting petitioners' tax liabilities for
1986, 1987, and 1988, respectively. At the same time, Mrs.
Callaway filed a Form 872-T with respondent, covering the taxable
years 1983 through 1990, along with a letter dated December 23,
1991, stating:
please accept this form as a statement disclaiming and
denying the Tax Matters Partners' settlement authority,
a statement denying the Tax Matters Partner's authority
to extend any statutes of limitation, and an election
to have any items which would be classified as
partnership items classified as non-partnership items
subject to the deficiency procedures of Internal
Revenue Code section 6213. * * *
There is no indication that respondent replied to Mrs. Callaway's
letters. However, the record indicates that respondent initially
concluded that Mrs. Callaway's request for prompt assessment of
income tax filed on behalf of decedent's estate was invalid.
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