-9-
partnership procedures.” (Emphasis added.) Consequently,
according to Mr. Hudspath, the Court should not sustain the
determinations in the affected items notice. Hudspath v. Commis-
sioner, T.C. Memo. 2004-75.
The Court rejected Mr. Hudspath’s position in petitioner’s
affected items proceeding (petitioner’s TEFRA-related case at
docket No. 14741-02) and sustained the determinations in the
affected items notice that there were additional deficiencies in
petitioner’s tax of $2,739 and $4,044 for 1996 and 1997, respec-
tively, but did not sustain the determination in that notice that
petitioner is liable for 1996 for the accuracy-related penalty
under section 6662(a). Id.
On or about April 19, 2003, respondent issued to petitioner
a final notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to petitioner’s
respective unpaid liabilities for his taxable years 1996 and 1997
that were attributable to flowthrough computational adjustments
resulting from the respective SCC-FPAA and WIN-FPAA (petitioner’s
respective unpaid liabilities for 1996 and 1997), which had been
the subject of the partnership-level proceeding (the TEFRA case
at docket No. 7982-00) that the Court dismissed for lack of
jurisdiction on April 2, 2001.6
6The notice of intent to levy did not include the respective
deficiencies of $2,739 and $4,044 for petitioner’s taxable years
(continued...)
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