Charles A. Greene and Christine J. Greene - Page 2

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          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.            

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