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ENERGY v. COMMISSIONER

Docket No. 1455-92.

67 T.C.M. 2620 (1994)

T.C. Memo. 1994-150

San Gabriel Energy, Anthony Kiss, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed April 12, 1994.

Attorney(s) appearing for the Case

Philip G. Panitz, 1200 Paseo Camarillo, Camarillo, Calif., for the petitioner. David A. Winsten, for the respondent.

Memorandum Opinion

CLAPP, Judge:

This case is before us on petitioner's motion for summary judgment filed pursuant to Rule 121. The issue is the validity of a Form 872-0 signed on behalf of the San Gabriel Energy partnership (the partnership) consenting to extend the statute of limitations with respect to the partnership's 1984 tax year, and the effect of a letter of discontinuance of audit erroneously issued to the partnership by respondent with regard...

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