- 5 -
through 1989. As a result of these losses and credits,
petitioners reported overpayments of tax for 1987 through 1990
and received refunds in the amounts claimed for at least 1987
through 1989.
Respondent issued Washoe Ranches and TBS 89-1 notices of
final partnership administrative adjustment (FPAAs) for at least
their 1990 and 1991 taxable years.5 After completion of the
partnership-level proceedings, respondent sent petitioners a Form
4549A-CG, Income Tax Examination Changes, reflecting changes made
for petitioners’ 1987 through 1991 tax years on May 22, 2002.
Respondent determined deficiencies in petitioners’ income tax of
$9,734, $11,717, $11,682, $8,445, and $9,492, respectively.
On June 3, 2004, respondent issued petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). The final notice included petitioners’
outstanding tax liabilities for 1987 through 1990.
In response to the final notice, petitioners submitted a
Form 12153, Request for a Collection Due Process Hearing.
5 The FPAAs are not in the record, nor are any other
details regarding the partnership-level proceedings. Apparently,
the tax matters partners for Washoe Ranches and TBS 89-1 filed
petitions with this Court in response to the FPAAs, and the Court
rendered an opinion in Durham Farms #1, J.V. v. Commissioner,
T.C. Memo. 2000-159, affd. 59 Fed. Appx. 952 (9th Cir. 2003).
While Durham Farms #1, J.V. lists TBS 89-1 as a petitioner, it
does not list Washoe Ranches. Mr. Lindley testified that, while
they became partners in Washoe Ranches, the partnership’s name
was later changed, which could explain the discrepancy.
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