John C. Bedrosian and Judith D. Bedrosian - Page 2




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          that the assessment of penalties relating to partnership                    
          adjustments is not subject to deficiency procedures, and that the           
          deficiencies in income tax were paid and assessed prior to the              
          issuance of the notice of deficiency.  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.  Respondent determined in an affected items notice            
          the following deficiencies in and penalties on petitioners’                 
          Federal income tax:                                                         
                                                   Penalty                           
          Year                Deficiency          Sec. 6662(a)                        
          1999         [2]$3,460,695          $1,399,552.80                           
          2000               12,137               4,854.80                            
               2   The deficiency in docket No. 12341-05 is $38,187                   
          greater than the deficiency listed above because the                        
               $38,187 was assessed as a computational adjustment.  See               
               infra pp. 4-5.                                                         
          The issues for decision are:  (1) Whether petitioners have                  
          previously paid a portion of the amount stated in the affected              
          items notice of deficiency, and (2) whether the Court lacks                 
          jurisdiction over the section 6662(a) penalties determined in the           
          affected items notice.                                                      




               1(...continued)                                                        
          on a statutory notice of deficiency sent to John and Judith                 
          Bedrosian.  Docket No. 9664-07 is a partnership-level proceeding            
          concerning the validity of a final partnership administrative               
          adjustment notice.                                                          





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