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income tax against individual partners, relative to partnership
items, has expired pursuant to sections 6501 and 6229.
The following facts are based upon the parties’ pleadings.
See Rule 120. They are stated solely for the purpose of deciding
the motion for judgment on the pleadings and not as findings of
fact in this case. See Fed. R. Civ. P. 52(a).
Background
G-5 Investment Partnership (G-5) filed a Form 1065, U.S.
Return of Partnership Income, for 2000 on October 4, 2001. Henry
M. Greene and his wife, Julie M. Greene (partners),2 were indirect
partners3 in G-5, and H. Miles Investments, L.L.C., was the tax
matters partner (TMP).4
On April 12, 2006, respondent issued a notice of final
partnership administrative adjustment (FPAA) for 2000. The FPAA
was issued more than 3 years after the filing of the partnership
return and the filing of the partners’ individual 2000 and 2001
2 For convenience, the Court uses the terms “partnership”
and “partner” without deciding whether a partnership existed, a
matter which respondent disputes.
3 The term “indirect partner” means a person holding an
interest in a partnership through one or more pass-thru partners.
Sec. 6231(a)(10). The term “pass-thru partner” means a
partnership, estate, trust, S corporation, nominee, or other
similar person through whom other persons hold an interest in the
partnership with respect to which proceedings under subch. C are
conducted. Sec. 6231(a)(9).
4 H. Miles Investments, L.L.C., is a single-member limited
liability company and a pass-thru partner with petitioner Henry
M. Greene as its member.
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Last modified: November 10, 2007