Robert W. and Vivian Toan - Page 2




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          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).                                                                     




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