-3-
to petitioner as the tax matters partner of SCC a notice of final
partnership administrative adjustment (FPAA) with respect to the
taxable years 1996 and 1997 of SCC (SCC-FPAA).2 In the SCC-FPAA,
the IRS notified petitioner as the tax matters partner of SCC
that SCC was a sham partnership because Fair Hollow Trust, one of
its partners, was a sham trust and that consequently SCC was
invalid because petitioner was the only partner.
On April 14, 2000, the IRS sent by certified mail to peti-
tioner as the tax matters partner of WIN an FPAA with respect to
the taxable years 1996 and 1997 of WIN (WIN-FPAA). In the WIN-
FPAA, the IRS notified petitioner as the tax matters partner of
WIN that Fair Hollow Trust, one of the partners of WIN, was a
sham trust created by petitioner and that consequently Fair
Hollow Trust’s share of the partnership items of WIN was allo-
cated to him.
On April 14, 2000 (the same date on which the IRS issued the
respective SCC-FPAA and WIN-FPAA to Mr. Hudspath as the tax
matters partner of each entity), the Commissioner sent him a
notice of deficiency for his taxable years 1996 and 1997 (1996
1(...continued)
ning of administrative proceeding.
2The IRS mailed the SCC-FPAA to 5436 Main Street, Stephens
City, Virginia 22655-2829, which is the address for petitioner
listed in the petition in the instant case.
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