- 2 - The sole issue for determination is whether respondent issued the notice of deficiency within the limitations period. Background 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 percent. 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), respondentPage: Previous 1 2 3 4 5 6 Next
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