Charles A. Greene and Christine J. Greene - Page 12

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               In June 1991, respondent proposed a settlement for taxable             
          years 1983 and 1984 regarding petitioner’s investment in Mid                
          Continent.  Petitioners rejected the proposed settlement on the             
          basis of the view that their tax liability was properly reported            
          on the amended return.                                                      
               On October 21, 1991, respondent mailed separate notices of             
          final partnership administrative adjustment (FPAA’s) to Mid                 
          Continent’s tax matters partner (TMP) for the taxable years 1983            
          and 1984.  Respondent did not mail a copy of either of the FPAA’s           
          to petitioners.  A timely petition for readjustment, which was              
          assigned docket No. 5757-92, was filed by partners other than the           
               On February 11, 1993, a decision was entered by this Court             
          in the partnership proceeding.  The decision served to sustain              
          respondent’s disallowance of the losses claimed by Mid Continent            
          on its partnership returns for 1983 and 1984.  No appeal was                
          taken, and this Court’s decision became final on May 12, 1993.              
          Secs. 7481(a), 7483.                                                        
               On December 27, 1993, respondent made an assessment against            
          petitioners, relating to the taxable year 1983, for additional              
          income tax in the amount of $5,000 and for unpaid interest in the           
          amount of $13,633.01 computed at the increased rate established             
          under section 6621(c).  The tax assessed in the amount of $5,000            
          was based on the disallowance of the remaining $10,000                      

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