- 5 - Examination of the Arid Land Partnership Petitioners received Schedules K-1 for the Arid Land partnership for tax years subsequent to 1983 displaying the tax identification number (TIN) 33-0026386. In the years 1991 and following, petitioners received Schedules K-1 for the "Blythe Jojoba Plantation, L.P." partnership. On July 2, 1990, the Internal Revenue Service (IRS) sent to petitioners by certified mail a Notice of Final Partnership Administrative Adjustment (FPAA) at "2 Paddock CT Lanoka Harbor NJ 08734-9278". Petitioners lived at 2 Paddock Court, Lanoka Harbor, New Jersey, from 1988 through the time of trial. The FPAA states that the IRS has determined adjustments to the partnership return of Arid Land Research Partners, TIN 33- 0026386. Upon respondent's motion at trial, we take judicial notice2 that on July 2, 1990, a petition in the name of Arid Land Research Partners, Robert E. Cole, Tax Matters Partner, was filed with the Court at docket No. 14600-90. The parties in the Arid Land case filed on November 1, 1993, a stipulation to be bound by 2See Fed. R. Evid. 201; United States v. Jackson, 640 F.2d 614, 617 (8th Cir. 1981)(Court may take judicial notice of its own records of prior litigation closely related to the case before it); Colonial Penn Ins. Co. v. Coil, 887 F.2d 1236, 1239- 1240 (4th Cir. 1989); St. Louis Baptist Temple, Inc. v. FDIC, 605 F.2d 1169, 1172 (10th Cir. 1979).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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