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INVESTMENT ENGINEERS, LTD. v. COMMISSIONER

Docket No. 9300-92.

71 T.C.M. 2407 (1996)

T.C. Memo. 1996-122

Investment Engineers, Ltd., Robert S. McGlamery, a Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 12, 1996.

Attorney(s) appearing for the Case

Robert S. McGlamery, pro se. Robert L. Montelius, Jr., tax matters partner, pro se. Sherri L. Munnerlyn, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

In a Notice of Final Partnership Administrative Adjustment (FPAA) sent December 3, 1991, respondent increased the income of Investment Engineers, Ltd. (the partnership), by $540,500 for 1982, $218,000 for 1983, and $123,000 for 1984. In Investment Engineers, Ltd. v. Commissioner [Dec. 49,888(M)], T.C. Memo. 1994-255, we concluded that the statute of limitations...

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