Alan H. Ginsburg and Estate of Harriet F. Ginsburg, Deceased, Alan H. Ginsburg, Personal Representative - Page 1

                                   127 T.C. No. 5                                     

                               UNITED STATES TAX COURT                                

              ALAN H. GINSBURG, PERSONAL REPRESENTATIVE, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13330-05.            Filed August 30, 2006.                 

                    A TEFRA partnership claimed losses from an                        
               investment.  See Tax Equity and Fiscal Responsibility                  
               Act of 1982 (TEFRA), Pub. L. 97-248, secs. 402-407(a),                 
               96 Stat. 648. Ps reported the losses as shareholders of                
               their two wholly owned S corporations, each of which                   
               owned a 50-percent interest in the partnership.  R                     
               examined the Federal tax return of the partnership.                    
               Subsequently, R sent a letter to the representative for                
               the partnership stating that R accepted the return as                  
               filed.  The partnership and R executed six consecutive                 
               Forms 872-P, Consent to Extend the Time to Assess Tax                  
               Attributable to Items of a Partnership, for the taxable                
               year 1995, the year at issue.  The time to assert                      
               partnership adjustments has expired pursuant to the                    
               Forms 872-P.  Ps and R executed nine consecutive Forms                 
               872, Consent to Extend the Time to Assess Tax, related                 
               to Ps’ 1995 Federal tax return.                                        

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