Elizabeth N. Callaway v. Commissioner of Internal Revenue

JUDGE POOLER concurs, in part, in a separate opinion.

LEVAL, Circuit Judge:

Elizabeth N. Callaway (“the taxpayer” or “Elizabeth”) appeals from so much of the March 10, 1998 Opinion and Order and the November 17, 1998 Decision of the United States Tax Court (Peter J. Panut-hos, Chief Special Trial Judge) that held that computational adjustments and subse*107quent affected items notices of deficiency issued to her were valid and were not time-barred. We have jurisdiction pursuant to I.R.C. § 7482(a).

This is a case of first impression in the Courts of Appeals, raising an issue of partnership taxation…