- 2 - and 1984 under section 6653(a)(1) in the amounts of $1,159.70 and $43.65, respectively. Respondent also determined for both years additions to taxes under section 6653(a)(2) in the amounts of 50 percent of the interest due on the portion of the underpayments of taxes attributable to negligence. Certain issues raised in this case by petitioners' Motion to Restrain Collection and respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike the Claims Relating to the Deficiency Attributable to Partnership Items and Increased Interest Pursuant to I.R.C. Section 6621(c) were decided by the Court in Greene v. Commissioner, T.C. Memo. 1995-105 (Greene I). By an amendment to petition, petitioners attempted to put at issue the period of limitations for the "deficiencies being assessed". The Court found that the affected items deficiency notices here involved were mailed to petitioners within 1 year of the date of entry of decision in the partnership level proceedings in docket No. 5757-92. See sec. 6229(d). The Court also found that petitioners were not entitled to direct notice of the partnership level proceedings and that any reliance on Crowell v. Commissioner, 102 T.C. 683 (1994), is misplaced. On brief petitioners state that they "believe that the Court has already ruled on the statute of limitations issue" in Greene I. We agree, and we decline to revisit the issue. See, e.g., Crocker v. Piedmont Aviation, Inc., 49 F.3d 735, 739 (D.C.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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