508 Clinton St. Corp. v. Commissioner
United States Tax Court
Respondent determined deficiencies in petitioner's personal holding company tax under sec. 541, I.R.C. 1954, for the fiscal years ended Sept. 30, 1979, and Sept. 30, 1982. Petitioner concedes that it is liable for the full amount of such deficiencies.
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Respondent determined deficiencies in petitioner's personal holding company tax under sec. 541, I.R.C. 1954, for the fiscal years ended Sept. 30, 1979, and Sept. 30, 1982. Petitioner concedes that it is liable for the full amount of such deficiencies. In its trial memorandum, however, petitioner asserts that respondent's denial of petitioner's request to abate the interest assessments attributable to such deficiencies violates the interest abatement provisions in sec. 6404(e), as enacted by the Tax Reform Act of 1986. Held, the Court lacks jurisdiction to address the interest abatement issue…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
By notice of deficiency dated December 6, 1985, respondent determined deficiencies in petitioner’s Federal personal holding company tax for the taxable years ended September 30, 1979, and September 30, 1982, in the amounts of $30,762 and $37,093, respectively.
The stipulation of settled issues is incorporated herein by this reference. Petitioner concedes that it is Hable for the fuU amount of the determined deficiencies. The only issue presented is whether respondent’s denial of petitioner’s request to abate the interest assessments attributable to the deficiencies…
2Cases cited21 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Breman v. CommissionerUnited States Tax Court · 1976
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
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- Horton Homes, Inc., N.D. Horton, Jr., Jacqueline P. Horton, N.D. Horton, Sr. And Maude Horton v. United StatesCourt of Appeals for the Eleventh Circuit · 1991
- Bourekis v. Comm'rUnited States Tax Court · 1998
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