Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:05-cv-00296-FMA

Document 85-2

Filed 03/31/2008

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS GRAPEVINE IMPORTS, LTD., a Texas Limited Partnership, and T-TECH, INC., a Texas Corporation as Tax Matters Partner, Plaintiffs, v. United States of America, Defendant. § § § § § § § § § §

Case No. 05-296T Judge Francis M. Allegra

ORDER DIRECTING ENTRY OF JUDGMENT The Court has considered the Joint Motion for Order filed by the parties to this case and finds the Joint Motion to be meritorious. The Joint Motion advises the Court that the Parties have settled all 2000 federal income tax liabilities attributable to the Notice of Final Partnership Administrative Adjustment ("FPAA") at issue in this case. The only remaining federal income tax attributable to the FPAA is 1999 tax assessable against Joseph and Virginia Tigue. The Court's Order entered on July 17, 2007, held, however, that the assessment against Joseph and Virginia Tigue of 1999 tax attributable to the FPAA is barred by the statute of limitations in 26 USC § 6501(a). Accordingly, it is therefore ORDERED that the assessment of tax against Joseph and Virginia Tigue for any year other than the 2000 tax year attributable to the FPAA is barred by the statute of limitations found in section 6501(a). This case is DISMISSED under 26 U.S.C. § 6226(d) because no partner has an interest in the outcome of this litigation. _______________________ Francis M. Allegra Judge Date:___________________