Epsolon Ltd. v. United States

OPINION AND ORDER

SWEENEY, Judge.

Before the court are Plaintiffs Motion for Summary Judgment (“Plaintiffs Motion” or “Pl.’s Mot.”) and Cross-Motion of the United States for Partial Summary Judgment, or in the Alternative, Motion Under Rule 56(f) (“Defendant’s Cross-Motion” or “Def.’s Cross-Mot.”). The issue presented is whether the Internal Revenue Service (“IRS”) failed to timely issue a Notice of Federal Partnership Administrative Adjustment (“FPAA”), thus rendering certain partnership items final and barring the IRS from proceeding against the partnership and the partners for additional…