Gary F. and Helen Overstreet - Page 2

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          The sole issue for determination is whether respondent issued the           
          notice of deficiency within the limitations period.                         
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  When the petition was filed, petitioners resided in              
          Los Angeles, California.                                                    
               In 1987, Mr. Overstreet’s law partnership, Finley, Kumble,             
          Wagner, Heine, Underberg, Manley, Myerson and Casey (Finley,                
          Kumble), ceased operation and dissolved.  On February 24, 1988,             
          several of Finley, Kumble’s creditor banks filed an involuntary             
          bankruptcy petition on behalf of Finley, Kumble, pursuant to                
          chapter 7 of the Bankruptcy Code, which the bankruptcy court, on            
          March 4, 1988, converted to a chapter 11 bankruptcy proceeding.             
          In 1992, some of Finley, Kumble’s debts were discharged in the              
          bankruptcy proceeding.                                                      
               Finley, Kumble’s original 1992 Form 1065, U.S. Partnership             
          Return of Income, filed on September 21, 1993, identified 280               
          general partners, including Mr. Overstreet and Marshall Manley.             
          Mr. Manley had the largest profit interest of any partner (i.e.,            
          5.6075 percent).  Mr. Overstreet’s profit interest was O.1680               
               On September 15, 1994, respondent began an examination of              
          Finley, Kumble’s 1992 partnership return.  Because Finley, Kumble           
          did not designate a tax matters partner (TMP), respondent                   

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