Transpac Drilling Venture 1982-22 v. Commissioner
United States Tax Court
Ps are notice partners of a partnership subject to the partnership audit and litigation provisions. R issued a notice of final partnership administrative adjustment on Apr. 14, 1986. The 90th day of the period for the tax matters partner to file a petition for readjustment fell on July 13, 1986, a Sunday. The tax matters partner has not filed a petition.
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Ps are notice partners of a partnership subject to the partnership audit and litigation provisions. R issued a notice of final partnership administrative adjustment on Apr. 14, 1986. The 90th day of the period for the tax matters partner to file a petition for readjustment fell on July 13, 1986, a Sunday. The tax matters partner has not filed a petition. Ps filed an identical petition in this case on July 15, 1986, and in docket No. 28322-86 on July 14, 1986. R has moved to dismiss the petition in this case as a duplicate petition. Held, the 90-day period of sec. 6226(a), I.R.C. 1954, for…
1Opinion of the Court
OPINION
WILLIAMS, Judge:
This case is before the Court on respondent’s motion to dismiss duplicate petition pursuant to Rule 53, Tax Court Rules of Practice and Procedure.
The Commissioner determined adjustments to the Federal partnership return of Transpac Drilling Venture 1982-22 as set forth in his notice of final partnership administrative adjustment issued on April 14, 1986. The issue this Court must decide is whether the petition for readjustment of partnership items, filed by the notice partners in this case pursuant to section 6226(b),1 was effective to commence a partnership action.
Respo…
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