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petitioners reported a 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. Neither the tax matters partner (TMP)
JCB, nor any notice partner filed a challenge to the FPAA before
the expiration of the periods prescribed in section 6226. 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.
That case is docket No. 12341-05.
On August 30, 2005, petitioners remitted $4,276,377 to the
IRS. The remittance was designated to cover $3,498,882 for the
1999 deficiency, $757,000 for estimated interest on the 1999
deficiency, $12,137 for the 2000 deficiency and $1,800 for the
estimated interest on the 2000 deficiency. Respondent treated
the remittance as a payment.
On September 1, 2006, respondent made the following
assessments against petitioners:
1999 2000
Deficiency attributable to $ 38,187
partnership items assessed
as a computational adjustment
Additional deficiency paid and 3,460,695 $12,137
assessed
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Last modified: March 27, 2008