Legal Opinion

Sente Inv. Club Partnership v. Commissioner

United States Tax Court

Decided September 11, 1990No. Docket No. 21056-87PublishedCited by 21 opinions

Sente Partnership (S) was a limited partner of D and E, two separate and distinct partnerships. D and E reported items of income, loss, and credit on their respective partnership returns for 1983 and 1984. R issued FPAA's with respect to D's 1983 partnership return and with respect to E's 1983 and 1984 partnership returns.

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Sente Partnership (S) was a limited partner of D and E, two separate and distinct partnerships. D and E reported items of income, loss, and credit on their respective partnership returns for 1983 and 1984. R issued FPAA's with respect to D's 1983 partnership return and with respect to E's 1983 and 1984 partnership returns. A petition was filed by S as a partner other than the tax matters partner in response to the FPAA issued to D. The petition was ultimately dismissed for failure to prosecute. No petition was filed in response to the FPAA issued to E. On its 1983 and 1984 partnership…

1Opinion of the Court

OPINION

RUWE, Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.2 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge:

This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike and petitioner’s motion to strike answer. The issues for decision are (1) whether this case must be dismissed for lack of jurisdiction to the extent the petition seeks redetermination of adjustments to…

2Cases cited3 opinions

  1. Maxwell v. CommissionerUnited States Tax Court · 1986
  2. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
  3. Saso v. CommissionerUnited States Tax Court · 1989

3Cited by21 opinions

  1. Jack Randell v. United StatesCourt of Appeals for the Second Circuit · 1995
  2. Walthall v. United StatesCourt of Appeals for the Ninth Circuit · 1997
  3. Brookes v. CommissionerUnited States Tax Court · 1997
  4. Boyd v. CommissionerUnited States Tax Court · 1993
  5. JENKINS v. COMMISSIONERUnited States Tax Court · 1994

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