128 T.C. No. 15
UNITED STATES TAX COURT
G-5 INVESTMENT PARTNERSHIP, H. MILES INVESTMENTS, LLC, TAX
MATTERS PARTNER, AND HENRY M. GREENE AND JULIE M. GREENE,
PARTNERS OTHER THAN THE TAX MATTERS PARTNER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17767-06. Filed May 30, 2007.
G-5 filed its partnership return for 2000 on Oct.
4, 2001. R issued a notice of final partnership
administrative adjustment (FPAA) to G-5 for 2000 on
Apr. 12, 2006, more than 3 years after the date of
filing of the partnership tax return and the filing of
the partners’ individual 2000 and 2001 Federal income
tax returns, but before the expiration of 3 years from
the dates the partners filed their individual 2002-04
Federal income tax returns.
R’s FPAA denied partnership losses in 2000. G-5’s
partners reported their distributive shares of partnership
losses for 2000 as capital loss carryovers on their
individual Federal income tax returns for 2002-04.
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Last modified: November 10, 2007