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Partnership Year Docket No.
River City Ranches #1, J.V.1 (RCR #1) 1986 787-91
River City Ranches #2, J.V. (RCR #2) 1986 787-91
1987 4876-94
River City Ranches #3, J.V. (RCR #3) 1986 787-91
1987 9550-94
River City Ranches #4, J.V. (RCR #4) 1984 14038-96
1986 787-91
River City Ranches #5, J.V. (RCR #5) 1986 787-91
1987 9552-94
1988 13597-94
River City Ranches #6, J.V. (RCR #6) 1986 787-91
River City Ranches 1985-2, J.V. (RCR 85-2) 1987 9554-94
1988 13599-94
1Petitioners use the designations of “Ltd.” and “J.V.”
interchangeably. For convenience, we use J.V. as used by
the parties in their briefs.
Second, we must decide whether the period of limitations on
assessment had expired when the notices of final partnership
administrative adjustment (FPAAs) were issued in the following
cases:4
4In River City Ranches #1 Ltd. v. Commissioner, 401 F.3d at
1144 n.5. (River City Ranches II), the Court of Appeals stated
that the record before it did not clearly identify which FPAAs
were filed within the default limitations periods and which were
filed under the disputed extensions. The parties agree that the
FPAAs in the above-listed dockets were issued after the
expiration of the 3-year default limitations period had expired.
FPAAs filed in other dockets before the Court of Appeals were
issued within the 3-year default limitations period.
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