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was capable of evaluating the risks and merits of investing in
Madison.
D. TEFRA Case
Mr. Greer was notified by the District Director of the
Internal Revenue Service (IRS) in New York City that an
examination of Madison’s partnership income tax return for 1982
had commenced by a letter sent on January 23, 1985. On December
24, 1987, the same District Director issued a Notice of Final
Partnership Administrative Adjustment for 1982 (FPAA) to Richard
Roberts, the Madison tax matters partner. Petitioners were sent a
copy of the FPAA on February 16, 1988. Following the issuance of
the FPAA, as the result of a petition filed on May 17, 1988,
petitioners became parties with other Madison partners in a
docketed case in this Court (docket No. 10601-88) under the TEFRA
provisions challenging the determinations made in the FPAA.
Over the next 13 years the following occurred: The denial of the
partners’ motion for summary judgment pursuant to Madison
Recycling Associates v. Commissioner, T.C. Memo. 1992-605, a
concession by the partners regarding the adjustments in the FPAA,
and an opinion, Madison Recycling Associates v. Commissioner, T.C.
Memo. 2001-85, finding that the FPAA was timely, which was
affirmed by Madison Recycling Associates v. Commissioner, 295 F.3d
280 (2d Cir. 2002). The result is that no dispute as to the
partnership adjustments in the FPAA for 1982 remains.
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