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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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