Dean and Rosalie Monahan - Page 3




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               In Anderson Equip. Associates, et al., Barrister Associates,           
          Tax Matters Partner v. Commissioner, docket No. 27745-89,                   
          respondent’s disallowance of the partnership losses and credits             
          claimed by Barrister and by other related partnerships was                  
          challenged by Barrister and by the other partnerships.                      
               On February 17, 1995, a settlement was entered into and an             
          agreed decision was entered in Anderson Equip. Associates                   
          reflecting the disallowance of the losses and credits claimed by            
          Barrister and by the other partnerships.  With respect to                   
          petitioners, the disallowance of Barrister’s claimed losses and             
          credits resulted in a tax deficiency for petitioners for 1982 of            
          $41,412.                                                                    
               On and about May 3, 1996, as a result of the disallowance of           
          Barrister’s claimed losses and credits, respondent issued                   
          affected-items notices of deficiency to petitioners and to the              
          other limited partners of Barrister and of the other related                
          partnerships.  The affected-items notice of deficiency that                 
          petitioner received from respondent asserted, among other things,           
          the additions to tax at issue herein.                                       
               Rosalie Monahan, a petitioner herein, also participated as             
          an executrix for a relative in the related case of Chimblo v.               
          Commissioner, 177 F.3d 119 (2d Cir. 1999), affg. T.C. Memo. 1997-           
          535.  Chimblo involved investments similar to those involved in             








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