- 3 -
began an examination of the partnership at some point in the mid-
1980's as part of a national project focusing on the various
partnerships of the Greenberg brothers.
Respondent issued notices of final partnership
administrative adjustments (FPAA's) determining adjustments to
partnership items for the following partnership taxable years:
Partnership
Docket No.4 FPAA Date Taxable Year Petition Date
623-92 Oct. 21, 1991 1983-1987 Jan. 8, 1992
13014-92 Mar. 24, 1992 1988 June 12, 1992
15641-92 Apr. 20, 1992 1989 July 10, 1992
12062-94 Mar. 14, 1994 1990 July 11, 1994
At the time the petitions in docket Nos. 623-92, 13014-92,
and 15641-92 were filed the partnership's principal place of
business was located at Greenwich, Connecticut. At the time the
petition in docket No. 12062-94 was filed the partnership was in
3(...continued)
Sylvester Stallone. We note that whether the partnership
obtained the benefits and burdens of ownership in the film is not
here at issue, but has formed the basis for considerable
securities litigation. See, e.g., Block v. First Blood
Associates, 988 F.2d 344, 347 (2d Cir. 1993), and cases cited
therein.
4
The petitions in docket Nos. 623-92, 13014-92, and
15641-92 were filed by the tax matters partner (TMP). The
petition in docket No. 12062-94 was filed by notice partner
Eugene C. Lipsky. Sec. 6226(b) provides in part that if the TMP
does not file a petition, then any notice partner may, within 60
days after the close of the 90-day period set forth in sec.
6226(a), file a petition for readjustment of partnership items
for the taxable year involved.
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