General Information Associates Partnership, Raymond and Irma Ziff, Partners Other Than The Tax Matters Partner
v.
Commissioner.
General Information Associates 3, William H. Chisholm and Alice J. Chisholm, Partners Other Than The Tax Matters Partner
v.
Commissioner.
United States Tax Court.https://leagle.com/images/logo.png
Filed September 29, 1992.
Filed September 29, 1992.
Attorney(s) appearing for the Case
Babcock MacLean and Robert B. Gluckman, 1345 Avenue of the Americas, New York, N.Y., for the petitioners in Docket No. 18405-90. Thomas E. Redding, for participants Seung C. Karl, Choong K. Kim, Moon K. Yoon, Eugene M. Rosol, Newton B. Schwartz, P.C., Robert P. Wiese, Richard J. Klamper, Walter S. Kawecki, Michael V. Raisor, Ivan Gingerich, Fenton Gingerich, Charles H. Scruggs, Loubess, Inc., and Norma Rosenblatt in Docket No. 18405-90. Linda S. Paine, for participants Mary Lee Harrell, Marshall Harrell III 1980 Trust, M.A. Harrell C/F M.A. Harrell III UGMA, and Marshall A. Harrell, Esq. in Docket No. 18405-90. Mark H. Berliant and Thomas C. Rink, for the petitioners in Docket No. 20111-90. James A. Halpin and George V. Chesteen, for participants E. Dennis and Katherine Christie, M. Warner and Patricia Westland, Norman P. and Joan E. Rounds, and Timothy and Mary McMullen in Docket No. 20111-90. William H. Stoddard III and Bruce M. Wilpon, for the respondent.
United States Tax Court.
Memorandum Opinion
BEGHE, Judge:
Respondent issued Notices of Final Partnership Administrative Adjustment (FPAA) for the taxable year 1983 for two partnerships: General Information Associates (GIA) and General Information Associates 3 (GIA3). Petitioners and Rule 245 participants (movants) have moved for partial summary judgment under Rule 121.1 Movants contend that the period of limitations expired before respondent issued the...
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