- 6 - respondent conceded that all assessments entered against decedent's estate were improper on the ground that Mrs. Callaway's request for prompt assessment filed on behalf of decedent's estate on December 23, 1991, was valid, thereby resulting in the immediate conversion of decedent's Mountain View partnership items to nonpartnership items under section 6231(c)(2) and section 301.6231(c)-8T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6794 (Mar. 5, 1987).3 In contrast, respondent maintained that the July 1996 assessments entered against Mrs. Callaway were proper on the ground that, notwithstanding the conversion of decedent's partnership items to nonpartnership items, Mrs. Callaway continued to be treated as a Mountain View partner pursuant to section 301.6231(a)(2)-1T(a), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987). Following a hearing on the matter, we denied petitioners' motion to restrain collection on the ground that the Court's jurisdiction in this case is limited to a redetermination of the additions to tax determined in the notices of deficiency for affected items at issue, and, therefore, the Court lacks the 3 As a result of respondent's concession respecting the validity of the request for prompt assessment filed on behalf of decedent's estate, respondent further concedes that respondent was obliged to issue a notice of deficiency to decedent's estate for (or assess) any deficiencies attributable to decedent's distributive share of Mountain View's partnership items for 1986, 1987, and 1988 by June 23, 1992. See secs. 6501(d), 6229(f).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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