- 2 - determination that petitioners were not entitled to a 1982 investment tax credit that they claimed was attributable to their interest in a limited partnership, Catamount Associates (Catamount), and portions of which they carried back to each of the subject years. Following actual and deemed concessions by petitioners, we must decide whether respondent is barred from assessing any of the amounts set forth in the notices of deficiency for the subject years.1 Petitioners assert that respondent is barred by either the 3-year period of limitation under section 6501 or a prior proceeding in this Court involving petitioners’ individual income tax liability for 1980. We hold that respondent may assess the additions to tax set forth in the notices of deficiency. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the relevant years. Rule references are to the Tax Court Rules of Practice and Procedure. 1 Petitioners set forth in their petition numerous allegations of error on the part of respondent. In their brief, petitioners limited their argument to the issue discussed herein. Under the facts of this case, we consider petitioners to have conceded all of their other allegations of error. See, e.g., Money v. Commissioner, 89 T.C. 46, 48 (1987); Burbage v. Commissioner, 82 T.C. 546, 547 n.2 (1984), affd. 774 F.2d 644 (4th Cir. 1985); Zimmerman v. Commissioner, 67 T.C. 94, 104 n.7 (1976).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011