- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011