Legal Opinion

Treaty Pines Investments Partnership v. Commissioner

Court of Appeals for the Fifth Circuit

Decided August 4, 1992No. 91-4631PublishedCited by 7 opinions

1Opinion of the Court

SNEED, Circuit Judge:

James A. Garrity and Andrea S. Garrity (“the Garritys”), as notice partners in Treaty Pines Investments Partnership (“Treaty Pines”), were involved in an adjustment proceeding before the U.S. Tax Court. The Garritys appeal the Tax Court’s denial of their motions to determine status as a party and to vacate a decision which purported to fix their liability as partners of Treaty Pines. They maintain that because they reached a settlement with the IRS in 1988, the Tax Court lacked subject matter jurisdiction as to their partnership items. We agree, and reverse and remand…

2Cases cited11 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
  3. Voluntary Purchasing Groups, Inc. v. William K. Reilly, Administrator, United States Environmental Protection AgencyCourt of Appeals for the Fifth Circuit · 1989
  4. Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
  5. Maria Emella Familia De Boom v. Arosa Mercantil, S.A. And Inversiones Calmer, S.A.Court of Appeals for the Fifth Circuit · 1980

6 more not listed; retrieve them via the Exa API.

3Cited by7 opinions

  1. Slovacek v. United StatesUnited States Court of Federal Claims · 1996
  2. Olson v. United StatesUnited States Court of Federal Claims · 1997
  3. Treaty Pines Investments Partnership v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
  4. Alexander v. United StatesDistrict Court, N.D. Texas · 1993
  5. Gingerich v. United StatesUnited States Court of Federal Claims · 2007

2 more not listed; retrieve them via the Exa API.

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