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On July 8, 1991, respondent issued notices of final
partnership administrative adjustment (FPAA's)4 to the TMP,
determining adjustments to partnership items for the 1983 through
1986 partnership taxable years. On October 7, 1991, the TMP
timely filed a petition with this Court on behalf of the
partnership for a readjustment of the partnership items. At the
time the petition in this case was filed, the partnership's
principal place of business was located at Greenwich,
Connecticut.
Almost 1 year after the filing of the petition in this case,
Mr. Long again wrote to Mr. Faber on the subject of the Greenberg
Brothers project, listing Lone Wolf in the subject portion of the
letter. The letter dated September 9, 1992, stated that
We are offering to settle the above referenced movie
tax shelters on the basis of an "at risk" settlement under
I.R.C. [sec.] 465. For purposes of the settlement taxpayers
are considered at risk to the extent of their initial cash
investment in the movie, with no amounts allowed for notes
executed by the partnership, or the assumption agreement
executed by the partners. After the cash is used up the
amount at risk is zero. However, to the extent the
partnership earns net income in later years, the amount at
risk will be increased in accordance with I.R.C. [sec.] 465.
4
The FPAA is the notice provided to affected taxpayer-
partners of respondent's final administrative adjustment for
specific partnership tax years. The FPAA is to the litigation of
partnership items the equivalent of the statutory notice of
deficiency in other cases. Sirrine Bldg. No. 1 v. Commissioner,
T.C. Memo. 1995-185, affd. without published opinion 117 F.3d
1417 (5th Cir. 1997).
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