Daniel C. Greer and Winnie L. Greer - Page 14

                                       - 14 -                                         
         was capable of evaluating the risks and merits of investing in               
         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.                        

Page:  Previous  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next 

Last modified: November 10, 2007