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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