Michael V. Domulewicz and Mary Ann Domulewicz - Page 3




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          the Court to redetermine respondent’s determination of a                    
          $2,398,491 deficiency in their 1999 Federal income tax and a                
          $946,750.80 accuracy-related penalty under section 6662(a).1                
          Those determinations were reflected in an affected items notice             
          of deficiency issued to petitioners after no partner of DMD                 
          Investment Partners (DIP) timely petitioned the Court with                  
          respect to a notice of final partnership administrative                     
          adjustment (FPAA) mailed to Michael Domulewicz (petitioner) as              
          DIP’s tax matters partner (TMP).  Copies of the FPAA also were              
          mailed to each of DIP’s other partners.                                     
               We decide the following issues:2                                       
               1.  Whether section 6230(a)(2)(A)(i) makes the deficiency              
          procedures of subchapter B of chapter 63 (deficiency procedures)            
          applicable to respondent’s disallowance of petitioners’ claim to            
          a passthrough loss from DMD Investments, Inc. (DII), an S                   
          corporation in which petitioner (through his grantor trust) was a           



               1 Unless otherwise indicated, section references are to the            
          applicable versions of the Internal Revenue Code.  Rule                     
          references are to the Tax Court Rules of Practice and Procedure.            
               2 We decide these issues with the aid of extensive briefing            
          by the parties.  The briefing was in the form of petitioners’               
          memorandum, respondent’s response, petitioners’ reply, and                  
          respondent’s response to reply.  After the Court filed                      
          respondent’s response to reply, petitioners moved the Court to              
          allow them to make their arguments at a hearing.  We shall deny             
          that motion.  The parties have adequately advanced their legal              
          arguments, and further arguments would not significantly aid our            
          decision process.  See Rule 50(b)(3).                                       





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