Taylor v. Comm'r
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Hoffman v. United StatesSupreme Court of the United States · 1951
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