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section 6225.1 See generally Kligfeld Holdings v. Commissioner,
128 T.C. 192 (2007), and Notice 2000-44, 2000-2 C.B. 255, for a
general description of the transaction in this case. Petitioners
petitioned the Court to redetermine respondent’s determination of
a $3,498,882 deficiency in their 1999 Federal income tax, a
$134,781.15 addition to tax pursuant to section 6651(a)(1) for
1999, a $1,392,552.80 accuracy-related penalty pursuant to
section 6662(a) for 1999, a $12,137 deficiency in their 2000
Federal income tax, and a $4,854.80 accuracy-related penalty
pursuant to section 6662(a) for 2000.2
The issue for decision is whether the Court lacks
jurisdiction to consider partnership and affected items in
response to a notice of deficiency issued prior to the completion
of partnership proceedings.
Background
Petitioners are husband and wife, and they resided in Los
Angeles, California, when their petition was filed.
JCB Stone Canyon Investments, LLC (JCB), a single member
limited liability company, and Stone Canyon Investors, Inc.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
2 This case involves the same or related parties as in
docket Nos. 24581-06 and 9664-07. Docket No. 24581-06 is based
on an affected items notice sent to John and Judith Bedrosian.
Docket No. 9664-07 is a partnership-level proceeding concerning
the validity of a notice of final partnership administrative
adjustment.
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Last modified: March 27, 2008