Tempest Assoc., Ltd. v. Commissioner
United States Tax Court
In docket No. 13298-88, on Feb. 1, 1988, R mailed a notice of Final Partnership Administrative Adjustment (FPAA) for the partnership's 1983, 1984, and 1985 taxable years addressed to the partnership's tax matters partner. At the time that the FPAA was mailed the tax matters partner was in bankruptcy.
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In docket No. 13298-88, on Feb. 1, 1988, R mailed a notice of Final Partnership Administrative Adjustment (FPAA) for the partnership's 1983, 1984, and 1985 taxable years addressed to the partnership's tax matters partner. At the time that the FPAA was mailed the tax matters partner was in bankruptcy. I, a partner other than the tax matters partner, filed a petition contesting R's determination for the taxable year 1985 within the time limit provided in sec. 6226(b). After the time limit provided in sec. 6226(b), I filed a motion for leave to file an amended petition. The amended petition…
1Opinion of the Court
OPINION
RUWE, Judge:
These cases were assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(4) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge:
These cases have been consolidated by the Court sua sponte, and they are before the Court on: (1) Petitioner’s motion for leave to amend petition, filed June 2, 1989, in docket No. 13298-88, and (2) respondent’s motion to dismiss for lack of jurisdiction, filed July 17, 1989, in docket No.…
2Cases cited8 opinions
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