- 22 - Madison investment. Petitioner also sought out other Madison partners and contacted approximately 30 companies to assess the relevant market. Additionally, petitioner contacted PI regarding the investment, went to look at the recyclers, proposed changes to Madison’s original business plan, and spent approximately 2 months attempting to have the recyclers at PI placed with end users. However, petitioner discontinued his efforts to resurrect Madison because PI was uncooperative. The Partnership Litigation On May 17, 1988, a partner other than Madison’s tax matters partner filed a petition in this Court (docket No. 10601-88) to challenge the determinations made in the FPAA. On April 9, 2001, we filed an opinion in docket No. 10601-88, see Madison Recycling Associates v. Commissioner, T.C. Memo. 2001-85, affd. 295 F.3d 280 (2d Cir. 2002), holding that Madison was a partnership subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648, and that the period of limitations on assessment had not expired before the FPAA was issued.16 The opinion was affirmed on appeal, and our decision sustaining respondent’s partnership adjustments became final on October 7, 2002. 16By the time we issued our opinion in Madison Recycling Associates v. Commissioner, T.C. Memo. 2001-85, affd. 295 F.3d 280 (2d Cir. 2002), the parties to the decision had agreed that respondent’s adjustments in the FPAA were correct.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011