Transpac Drilling Venture, 1983-2 by James M. Dobbins v. United States

FRIEDMAN, Senior Circuit Judge.

The question in this case is whether the United States Court of Federal Claims correctly held that assessments of additional partnership tax liability made by the Commissioner of Internal Revenue were timely. See Transpac Drilling Venture, 1983-2 v. United States, 32 Fed. Cl. 810 (1995). The assessments resulted from the disallowance of improperly taken business deductions. We affirm.

I

A. The basic facts, as set forth in the opinion of the Court of Federal Claims, are undisputed.

The appellant, Transpac Drilling Venture 1983-2 (Transpac), is one of a group of 51…