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respondent mailed FRC a Notice of Final Partnership
Administrative Adjustment (FPAA). In the notice, respondent
determined that FRC could not use PCM to calculate the income
attributable to the aforementioned property transactions and that
FRC underreported its gross receipts by $90,801,873.
On December 18, 1995, Hon Property Investments, Inc., on
behalf of FRC, filed a petition. On the date the petition was
filed, FRC was comprised of Hon Property Investments, Inc., Hon
Family Trust, Hon Family Ventures, Ltd., Hon Irrevocable Income
Trust, and Buck Equities, Ltd. On February 16, 1996, respondent,
contending that Hon Property Investments, Inc., was not FRC's tax
matters partner, filed a motion to dismiss for lack of
jurisdiction. FRC subsequently amended the petition to list Buck
Equities, Ltd., as the tax matters partner, and on September 17,
1996, we denied respondent's motion. On November 4, 1996,
respondent filed his answer.
Petitioner on January 30, 1997, filed a motion for summary
judgment contending that, pursuant to section 6229(a), the 3-year
period of limitations on assessment was applicable and this
period had expired before respondent issued the FPAA. The
parties subsequently settled the case and filed a stipulation,
which made no adjustments to FRC's reported income. Petitioner,
on June 10, 1997, filed its motion for litigation costs.
Discussion
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