- 25 - you should not raise any penalty issues should you decide to petition the Tax Court with respect to this FPAA. On June 12, 1989, a case was commenced in this Court at docket No. 13191-89 and captioned “Dickinson Recycling Associates, Sam Winer, Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent”.10 Subsequently, on February 23, 1994, the Court entered decision in the Dickinson case pursuant to the Commissioner’s Motion for Entry of Decision under Rule 248(b). The Court’s decision, which reflected the full concession by Dickinson of all items of income, loss, and the underlying valuation for the recyclers for 1982 through 1985, completely sustained the Commissioner’s FPAA determinations for those years. J. Payment of Additional Interest by Petitioners In November 1994, after the Court’s decision in the partnership action at docket No. 13191-89 became final, respondent mailed a letter to petitioners advising them that their amended return related to Dickinson for the taxable year 1982 had been accepted as filed11 and that the provisions of 10 All of the limited partners of Dickinson who had an interest in the outcome of the partnership proceeding were treated as parties to the proceeding. See sec. 6226(c) and (d). See also Title XXIV, Tax Court Rules of Practice and Procedure, regarding partnership actions. 11 In September 1988, petitioners amended their income tax returns for 1982 through 1985. Copies of those returns are not (continued...)Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011