Law Office of John H. Eggertsen P.C. v. Comm'r
United States Tax Court
R filed a motion for reconsideration of findings or opinion in Law Office of John H. Eggertsen P.C. v. Commissioner, 142 T.C. 110 (Feb. 12, 2014) (Eggertsen I), and a motion to vacate decision (collectively, R's motions). In Eggertsen I, we addressed whether I.R.C. sec. 4979A(a) imposes a Federal excise tax (excise tax) on P for its taxable year 2005. We held that it does.
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R filed a motion for reconsideration of findings or opinion in Law Office of John H. Eggertsen P.C. v. Commissioner, 142 T.C. 110 (Feb. 12, 2014) (Eggertsen I), and a motion to vacate decision (collectively, R's motions). In Eggertsen I, we addressed whether I.R.C. sec. 4979A(a) imposes a Federal excise tax (excise tax) on P for its taxable year 2005. We held that it does. We also addressed in Eggertsen I whether the period of limitations for assessing that tax has expired (statute of limitations issue). It was R's position with respect to the statute of limitations issue in Eggertsen I that…
1Opinion of the Court
SUPPLEMENTAL OPINION
Chiechi, Judge:
This case is before us on respondent’s motion for reconsideration of findings or opinion (respondent’s motion for reconsideration) and respondent’s motion to vacate decision (respondent’s motion to vacate). 1 We shall grant respondent’s motions.
Background
We incorporate herein by reference the facts set forth in Law Office of John H. Eggertsen P.C. v. Commissioner, 142 T.C. 110 (2014) (Eggertsen I). 2 We repeat here only those facts relevant to this Supplemental Opinion.
At all relevant times, 100% of the stock of petitioner was allocated to John H. Eggertsen…
2Cases cited15 opinions
- Beard v. Comm'rUnited States Tax Court · 1984
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
10 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Gwendolyn L. Kestin v. CommissionerUnited States Tax Court · 2019
- Law Office of John H. Eggertsen P.C. v. CommissionerUnited States Tax Court · 2014