- 5 - Winer. On February 23, 1994, respondent's proposed decision was entered as the decision of the Court. Neither participants nor any other partner objected to the entry of decision, and no appeal was taken from the decision. Pursuant to sections 6230(a)(1) and 6231(a)(1) and (6), the deficiencies attributable to the disallowed Davenport partnership items were assessed by computational adjustments against Davenport's limited partners, including participants, at the conclusion of the partnership level proceedings. Almost 2 years after the entry of decision in this case, on January 23, 1996, participants filed with this Court a Motion for Leave to File Election to Participate and submitted a Notice of Election to Participate in the captioned matter involving Davenport. By order dated February 15, 1996, we granted participants' motion to file a notice of election to participate in the captioned matter involving Davenport. Also on January 23, 1996, participants filed a Motion for Special Leave to File Motion for Reconsideration of Decision or to Vacate Decision in the captioned matter involving Davenport. On the same date participants lodged with the Court a Motion For Reconsideration of Decision or to Vacate Decision. Participants' motion for special leave is currently pending before this Court. The resolution of these matters turns on whether the petition to this Court signed by Winer on behalf of the partnership is valid for purposes of conferring jurisdiction on this Court and also onPage: 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