- 12 - 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 TMP. 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 $10,000Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011