Larry J. and Sherilyn Wadsworth - Page 9

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          ground T.C. Memo. 1990-380; Clapp v. Commissioner, 875 F.2d 1396,           
          1402 (9th Cir. 1989).                                                       
               Those circumstances are not present in this case.  Unlike              
          the notice of deficiency in Scar, the notice of deficiency in               
          this matter clearly disallowed amounts claimed on petitioners’              
          2001 and 2002 amended returns:  the notice disallowed the amounts           
          of $990,700 and $165,116 claimed as reductions to Mr. Wadsworth’s           
          distributive share of income from Gold Coast for 2001 and 2002,             
          respectively.  Although the notice of deficiency does not                   
          identify Gold Coast by name, it does determine deficiencies of              
          $147,708 and $56,958 for 2001 and 2002 respectively.  Those                 
          amounts are identical to the refunds claimed on petitioners’ 2001           
          and 2002 amended returns.  The notice of deficiency in this                 
          matter therefore did not reveal on its face that respondent                 
          failed to make a determination with regard to petitioners’ 2001             
          and 2002 tax liabilities.  Consequently, we reject petitioners’             
          argument that the notice of deficiency cannot serve as the basis            
          of our jurisdiction because it is not the product of an actual              
          determination of respondent.                                                
               Petitioners also argue that this Court lacks jurisdiction to           
          decide whether they received income from Gold Coast because Gold            
          Coast is subject to the unified partnership procedures of                   
          sections 6221 through 6233.  See Tax Equity and Fiscal                      

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