- 2 -
Background
Petitioner Jean Mathia resided in Grove, Oklahoma, when she
petitioned this Court on her own behalf and as personal
representative of the Estate of Doyle V. Mathia, her deceased
husband. Doyle V. Mathia (Mr. Mathia) and petitioner were
married and filed joint income tax returns for all relevant tax
years. Mr. Mathia died on February 19, 2000.
Mr. Mathia was a limited partner in Greenwich Associates
(Greenwich), a New York limited partnership subject to the
unified audit and litigation procedures of the Tax Equity and
Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec.
402(a), 96 Stat. 648, for the relevant tax years. He owned an
8.484-percent limited partnership interest in Greenwich at all
relevant times. Kevin Smith was the general partner and tax
matters partner (the TMP) of Greenwich.2
On August 3, 1990, the Commissioner issued Greenwich a
Notice of Final Partnership Administrative Adjustment for 1982
through 1984. The TMP timely filed a petition for review in this
Court pursuant to section 6226 (the Greenwich litigation).3 On
2Sec. 6224(c)(3) authorizes the tax matters partner of a
partnership, as defined by the Code, to enter into a settlement
agreement that is binding on all partners who are not notice
partners or members of a notice group, i.e., those partners not
entitled to notice of administrative proceedings with respect to
the partnership.
3Docket No. 24102-90.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011