Legal Opinion

Taylor v. Comm'r

United States Tax Court

Decided April 6, 2006No. 21744-03Unpublished

P filed Federal income tax returns for P and two LLCs for 1999 and 2000. R subsequently determined deficiencies and penalties with respect to P's income taxes, which P contested primarily on the basis of tax protester arguments. P also argued that R did not provide to either of the LLCs a final partnership administrative adjustment and therefore the deficiency notice mailed to her was premature.

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P filed Federal income tax returns for P and two LLCs for 1999 and 2000. R subsequently determined deficiencies and penalties with respect to P's income taxes, which P contested primarily on the basis of tax protester arguments. P also argued that R did not provide to either of the LLCs a final partnership administrative adjustment and therefore the deficiency notice mailed to her was premature. Held: Following a concession by R, P is liable for the remaining deficiencies, except for an adjustment for a reduced share of income from one LLC in 1999, determined by R for 1999 and 2000 including…

1Opinion of the Court

SUE TAYLOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Taylor v. Comm'r

No. 21744-03

United States Tax Court

T.C. Memo 2006-67; 2006 Tax Ct. Memo LEXIS 68; 91 T.C.M. (CCH) 969; RIA TM 56473;

April 6, 2006, Filed

P filed Federal income tax returns for P and two LLCs for 1999

and 2000. R subsequently determined deficiencies and penalties

with respect to P's income taxes, which P contested primarily on

the basis of tax protester arguments. P also argued that R did

not provide to either of the LLCs a final partnership

administrative adjustment and therefore the deficiency notice

mailed to her…

2Cases cited43 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  5. Hoffman v. United StatesSupreme Court of the United States · 1951

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