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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).
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