Estate of Robert W. Quick, Deceased, Esther P. Quick, Personal Representative, and Esther P. Quick - Page 1

                                   110 T.C. No. 17                                    

                               UNITED STATES TAX COURT                                

                ESTATE OF ROBERT W. QUICK, DECEASED, ESTHER P. QUICK,                 
            PERSONAL REPRESENTATIVE, AND ESTHER P. QUICK, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8588-97.                    Filed March 16, 1998.           

                    P was a limited partner in a partnership subject                  
               to the unified audit and litigation provisions of the                  
               Tax Equity and Fiscal Responsibility Act of 1982                       
               (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324,                    
               648.  R issued notices of computational adjustment to                  
               Ps, pursuant to which deficiencies for taxable years                   
               1987 through 1990 were assessed.  In the computational                 
               adjustment notices for 1989 and 1990, R recharacterized                
               Ps' distributive share of partnership losses for those                 
               years as passive for purposes of sec. 469, I.R.C.  R                   
               thereafter issued affected items notices of deficiency                 
               to Ps for 1987 through 1990 in which additions to tax                  
               and accuracy-related penalties were determined, based                  
               on the computational adjustments.  Secs. 6653(a)(1)(A)                 
               and (B), 6659, 6661, 6662(a), I.R.C.  Ps moved for                     
               summary judgment, claiming that the period of                          
               limitations for assessment for 1989 and 1990 has                       
               expired such that Ps' share of partnership losses                      

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