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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’s
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Last modified: May 25, 2011