Legal Opinion
Highpoint Tower Technology Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided July 24, 2019No. 18-10394PublishedCited by 11 opinions
1Opinion of the Court
ANDERSON, Circuit Judge:
This is an appeal by Highpoint Tower Technology, Inc. ("Highpoint") of *1052 the Tax Court's denial of its Motion to Restrain Collection of the gross valuation-misstatement penalty, I.R.C. § 6662(h)(1), which was determined to be applicable during relevant partnership proceedings. The issue in this case is whether, under the Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA"), 2 a Tax Court presiding over partner-level deficiency proceedings has jurisdiction over a gross valuation-misstatement penalty previously determined to be applicable at the partnership level…
2Cases cited18 opinions
- Harris v. GarnerCourt of Appeals for the Eleventh Circuit · 2000
- United States v. WoodsSupreme Court of the United States · 2013
- CBS Inc., Fox Broadcasting Co. v. Primetime 24 Joint VentureCourt of Appeals for the Eleventh Circuit · 2001
- Kligfeld Holdings v. Comm'rUnited States Tax Court · 2007
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
13 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- David B. Greenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021
- United States v. B.G.G.Court of Appeals for the Eleventh Circuit · 2022
- Alan H. Ginsburg v. United StatesCourt of Appeals for the Eleventh Circuit · 2021
- Raghunathan Sarma v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2022
- Kaylan A. Lewis v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2023
6 more not listed; retrieve them via the Exa API.