Estate of Quick v. Commissioner
United States Tax Court
P was a limited partner in a partnership subject to the unified audit and litigation provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. R issued notices of computational adjustment to Ps, pursuant to which deficiencies for taxable years 1987 through 1990 were assessed.
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P was a limited partner in a partnership subject to the unified audit and litigation provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. R issued notices of computational adjustment to Ps, pursuant to which deficiencies for taxable years 1987 through 1990 were assessed. In the computational adjustment notices for 1989 and 1990, R recharacterized Ps' distributive share of partnership losses for those years as passive for purposes of sec. 469, I.R.C. R thereafter issued affected items notices of deficiency to Ps for 1987…
1Opinion of the Court
OPINION
NlMS, Judge:
This matter is before the Court on the following three motions: (1) Petitioners’ motion for leave to file amendment to petition pursuant to Rule 41(a); (2) respondent’s motion for leave to file amendment to answer pursuant to Rule 41(a); and (3) petitioners’ motion for summary judgment filed pursuant to Rule 121.
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined additions to, and penalties on, the…
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