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A. The Harlans
The Harlans filed their joint 1985 tax return on or about
August 12, 1986. On June 26, 1992, respondent issued a notice of
deficiency to the Harlans for 1985.
The 3-year period of limitations for assessment of tax under
section 6501(a) with respect to the Harlans for 1985 expired
before the notice of deficiency was mailed. The Harlans did not
execute any extensions of the period of limitations on assessment
with respect to 1985.
The Harlans’ 1985 tax return has attached to the Form 1040,
the following: Schedules A, B, C, D, E, and SE; Forms 3468,
3800, 4136, 4797, 4868, 6251, 1116, 2210, 4562, 4835, 4952; 27
numbered “statements”; and a Treasury Department Form TD F 90-
22.1.
The Harlans’ 1985 tax return shows an ordinary loss of
$56,069 from several partnerships, identified by name, address,
and employer identification number. The record includes 1985
partnership information returns, or parts of those returns, from
each of the identified partnerships, as well as stipulations as
to the Harlans’ shares of the partnerships’ gross incomes,
determined without regard to the 2d-tier partnership gross
incomes.
During 1985, Ridge was a partner in three single-tier
partnerships, and Marjorie was a partner in one single-tier
partnership.
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