Malone v. Comm'r
United States Tax Court
Ps were partners of a partnership that was subject to the unified audit and litigation procedures of I.R.C. secs. 6221-6234. Ps did not report their share of partnership items on their return and did not file a notice of inconsistent treatment. See generallyI.R.C. sec. 6222. R assessed the tax attributable to the partnership items as originally reported by the partnership.
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Ps were partners of a partnership that was subject to the unified audit and litigation procedures of I.R.C. secs. 6221-6234. Ps did not report their share of partnership items on their return and did not file a notice of inconsistent treatment. See generallyI.R.C. sec. 6222. R assessed the tax attributable to the partnership items as originally reported by the partnership. In this deficiency proceeding, R asserted a negligence penalty relating to Ps' failure to report partnership items. Ps moved to dismiss the penalty from this case, asserting that we lack jurisdiction over a penalty relating…
1Opinion of the Court
BERNARD P. MALONE AND MARY ELLEN MALONE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Malone v. Comm'r
Docket No. 22750-09.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 17; 148 T.C. No. 16;
May 1, 2017, Filed
An appropriate order will be issued.
Ps were partners of a partnership that was subject to the unified audit and litigation procedures of I.R.C. secs. 6221-6234. Ps did not report their share of partnership items on their return and did not file a notice of inconsistent treatment. See generallyI.R.C. sec. 6222. R assessed the tax attributable to the partnership items as…
2Cases cited9 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- White v. CommissionerUnited States Tax Court · 1990
- Crowell v. CommissionerUnited States Tax Court · 1994
- Roberts v. CommissionerUnited States Tax Court · 1990
4 more not listed; retrieve them via the Exa API.