Foothill Ranch Company Partnership, Buck Equities, Ltd., Tax Matters Partner - Page 4

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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.                    

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