Estate of James T. Callaway, Deceased, Elizabeth N. Callaway, Executrix, and Elizabeth N. Callaway - Page 4

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               On October 5, 1992, respondent issued notices of final                 
          partnership administrative adjustment (FPAA) to the tax matters             
          partner (TMP) for Mountain View determining adjustments to the              
          partnership's tax returns for 1986, 1987, and 1988.  On the same            
          date, respondent mailed to petitioners copies of the above-                 
          described FPAA's.                                                           
               On or about March 17, 1993, a Mountain View partner, other             
          than the TMP, filed a petition for readjustment with the U.S.               
          Court of Federal Claims contesting the FPAA's described above.              
               In August and September 1993, respondent entered what                  
          respondent terms "precautionary" assessments against petitioners            
          for additional taxes in the amounts of $77,384, $41,981, and                
          $6,541 for 1986, 1987, and 1988, respectively, reflecting the               
          disallowance of decedent's distributive share of Mountain View's            
          partnership items for those years.  At the same time, respondent            
          posted to petitioners' accounts the amounts that Mrs. Callaway              
          remitted to respondent on December 23, 1991.2                               
               On July 6, 1995, the U.S. Court of Federal Claims dismissed            
          the partnership level action pursuant to section 6226(h) based              
          upon a stipulation for dismissal in which the partnership                   
          conceded the adjustments set forth in the FPAA's.                           

          2  Respondent entered these assessments in an effort to                     
          protect against the expiration of the period of limitations in              
          the event that Mrs. Callaway's request for prompt assessment                
          filed on behalf of the decedent's estate was deemed valid.                  

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