River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 4




                                        - 4 -                                         
                           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.                        





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007