- 4 - 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.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