Estate of Robert W. Quick, Deceased, Esther P. Quick, Personal Representative, and Esther P. Quick - Page 7

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          deficiencies in the amounts of $48,366 and $101,879,                        
          respectively, which reflect respondent's position that all of the           
          Partnership's losses for those years (including the losses                  
          reported prior to the entry of the Decision) should be                      
          recharacterized as passive losses in petitioners' hands, subject            
          to the limitations of section 469.  On March 17, 1997, respondent           
          assessed the deficiencies for 1987 through 1990 arising from the            
          foregoing computational adjustments.                                        
               On March 7, 1997, respondent issued to petitioners affected            
          items notices of deficiency for 1987 and 1988 determining                   
          additions to tax only, based on the computational adjustments for           
          those years.  On March 14, 1997, respondent issued to petitioners           
          penalties-only affected items deficiency notices for 1989 and               
          1990, based on the computational adjustments for those years.               
               Based on information subsequently received from petitioners'           
          counsel, respondent abated the assessments for 1989 and 1990 and,           
          with petitioners' consent, attempted to rescind the related                 
          penalties-only March 14, 1997, notices pursuant to section                  
          6212(d).  However, upon learning of respondent's intention to               
          issue new affected items notices of deficiency for 1989 and 1990            
          determining both deficiencies and penalties, petitioners revoked            
          their consent to rescind the March 14, 1997, notices in a letter            
          to respondent dated April 24, 1997.  On May 1, 1997, petitioners            
          filed the petition herein.                                                  






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