John C. Bedrosian and Judith D. Bedrosian - Page 4




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          distributive share of long-term capital loss from Investors of              
          $17,250,088 for 1999.                                                       
               On April 8, 2005, respondent issued a notice of final                  
          partnership administrative adjustment (FPAA) to the partners of             
          Stone Canyon for 1999.  Eleven days after the FPAA was issued,              
          respondent issued petitioners a statutory notice of deficiency              
          for 1999 and 2000.  Petitioners timely petitioned the Court to              
          review the notice of deficiency.                                            
                                     Discussion                                       
          I.  Respondent’s Motion To Dismiss                                          
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent provided by                    
          Congress.  See sec. 7442; see also GAF Corp. & Subs. v.                     
          Commissioner, 114 T.C. 519, 521 (2000).  We have jurisdiction to            
          redetermine a deficiency if a valid notice of deficiency is                 
          issued by the Commissioner and if a timely petition is filed by             
          the taxpayer.  GAF Corp. & Subs. v. Commissioner, supra at 521.             
               The partnership-level proceeding described in sections 6221            
          through 6234 requires that all challenges to adjustments of                 
          partnership items contained in the FPAA are to be made in a                 
          single unified proceeding.  Under these procedures, the tax                 
          treatment of any partnership item shall be determined at the                
          partnership level.  Sec. 6221.                                              








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