- 4 - that petitioners’ amended income tax returns failed to properly report Mr. Wadsworth’s alleged distributive share of the income of Gold Coast. On June 13, 2005, petitioners timely petitioned this Court for a redetermination of the 2001 and 2002 deficiencies. In their petition, petitioners argued that the notice of deficiency was invalid because: (1) The notice of deficiency is vague and incomprehensible; and (2) the adjustments at issue are subject to the partnership-level proceedings of sections 6221 through 6233, and respondent therefore lacks authority to assert a deficiency against an individual partner before the issuance of a notice of final partnership administrative adjustment (FPAA). After receiving an extension of time to file, respondent timely filed his answer to the petition on August 29, 2005. Paragraph 8 of respondent’s answer consists of detailed allegations regarding Gold Coast’s income for 2001 and 2002 and Mr. Wadsworth’s involvement in Gold Coast. Respondent alleges, inter alia, that Mr. Wadsworth was a 50-percent partner in Gold Coast; that Gold Coast had only two partners, both of whom were individuals; that Gold Coast operated a pharmacy that provided medical products and services to eligible beneficiaries of the California Medical Assistance Program; that the California Department of Health Services (DHS) conducted an audit of Gold Coast’s records for the period from January 1, 2001, throughPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011