N.C.F. Energy Partners v. Commissioner
United States Tax Court
R issued a notice of final partnership administrative adjustment to N.C.F. The accompanying explanation of items referred to additions to tax that R intended to assert at the partner level at the conclusion of the partnership proceeding. P's petition asserts that R erred in determining the additions to tax. R moved to dismiss and to strike that part of the petition that relates to redetermining the additions to tax in the partnership proceeding.
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R issued a notice of final partnership administrative adjustment to N.C.F. The accompanying explanation of items referred to additions to tax that R intended to assert at the partner level at the conclusion of the partnership proceeding. P's petition asserts that R erred in determining the additions to tax. R moved to dismiss and to strike that part of the petition that relates to redetermining the additions to tax in the partnership proceeding. Held, a partnership proceeding is designed to resolve only disputes over the proper treatment of partnership items; sec. 6221, I.R.C. 1954. Held,…
1Opinion of the Court
OPINION
WILLIAMS, Judge:
This case is before us on respondent’s motion to dismiss for lack of jurisdiction and to strike that portion of the petition that relates to redetermining in this partnership proceeding the additions to tax pursuant to sections 6653(a)(1),1 6653(a)(2), 6659, 6661, and 6621(c). In his Notice of Final Partnership Administrative Adjustment (FPAA) issued to petitioner Bingham Petroleum, Inc., tax matters partner of N.C.F. Energy Partners (N.C.F.) on March 4, 1986,2 the Commissioner determined adjustments to N.C.F.’s partnership returns for its 1982 and 1983 taxable years.…
2Cases cited1 opinion
- Maxwell v. CommissionerUnited States Tax Court · 1986
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- White v. CommissionerUnited States Tax Court · 1990
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