127 T.C. No. 5
UNITED STATES TAX COURT
ALAN H. GINSBURG AND ESTATE OF HARRIET F. GINSBURG, DECEASED,
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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