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Partnership’s Return; FPAA; Petition; Participating Partners
The partnership timely made a return of income for its 1986
taxable (calendar) year (the 1986 partnership return). By notice
of final partnership administrative adjustment, dated March 14,
1990 (the FPAA), respondent made adjustments to the 1986
partnership return. The petition was filed on June 13, 1990, by
George P. and Ann T. Ballas, two partners other than the tax
matters partner (the petitioning partners). The petitioning
partners are no longer parties to this case, having entered into
settlement agreements with respondent on April 28, 1997, with
respect to the partnership items in question. Following the
elimination of the petitioning partners from the case, the case
was carried on by respondent and certain other partners who had
elected to participate in the case. On June 28, 1999, petitioner
intervened. Petitioner is a general partner of the partnership,
and he has been the tax matters partner (TMP) since at least
June 13, 1990. Petitioner is, now, the only participating
partner.
FPAA Adjustments and Issues Raised in the Petition
By the FPAA, respondent notified the TMP that he was
disallowing Schedule F, Profit or Loss From Farming, deductions
of the partnership (the Schedule F deductions) in the amount of
$10,104,861. Respondent explained his disallowance of the
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Last modified: May 25, 2011