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CASCADE PARTNERSHIP v. COMMISSIONER

Docket No. 18078-90.

71 T.C.M. 3226 (1996)

T.C. Memo. 1996-299

Cascade Partnership, James M. and Margaret C. Costello, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed June 26, 1996.

Attorney(s) appearing for the Case

Larry N. Johnson, for the petitioner. Edward D. Fickess, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

The parties, by means of cross-motions for partial summary judgment, seek resolution of their controversy over whether the period for assessment had expired at the time respondent mailed the Notice of Final Partnership Administrative Adjustment (FPAA). More specifically, the question we consider is whether a consent (to extend the period for assessment) executed by one of the partnership's general partners, effectively extended...

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