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HIGHWOOD PARTNERS v. COMMISSIONER OF INTERNAL REVENUE

No. 24463-06.

133 T.C. No. 1

HIGHWOOD PARTNERS, B & A HIGHWOODS INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed August 13, 2009.

Attorney(s) appearing for the Case

David D. Aughtry and William E. Buchanan, for petitioner.

William F. Castor, for respondent.

OPINION

GOEKE, Judge.

This case is before the Court on the parties' cross-motions for summary judgment pursuant to Rule 121.1 Petitioner filed a motion for summary judgment arguing that respondent failed to issue the FPAA before the expiration of the 3-year limitations period provided in section 6501(a). Respondent opposes petitioner's motion and has filed a cross-motion for partial summary judgment arguing that the 6-year limitations...

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