- 2 - Items Under Code Section 6226. After concessions, the sole remaining issue is whether disclosures made in the 1990 Federal income tax returns of Western and of partnerships in which Western owned interests were adequate to apprise respondent of the nature and amount of omitted items and, thereby, to preclude the application of the 6-year period of limitations under section 6229(c)(2). This issue is before the Court on cross-motions for summary judgment pursuant to Rule 121. The record shows, and the parties agree, that there is no genuine issue of material fact. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background Western is a Delaware limited partnership whose principal place of business was Boston, Massachusetts. Petitioner is a corporation organized under Delaware law. Western’s sole activity was selling, to a third-party buyer, Western’s 84-percent partnership interests in CC&F Bellevue Office Investment Co. (Bellevue), CC&F Cabot Plaza II Investment Co. (Cabot Plaza), CC&F Chatsworth Investment Co. (Chatsworth), CC&F Diamond Bar Investment Co. (Diamond Bar), CC&F Issaquah I Investment Co. (Issaquah), CC&F Mira Loma Investment Co. (Mira Loma), and CC&F Topanga Investment Co. (Topanga); Western’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011