Legal Opinion

Malone v. Comm'r

United States Tax Court

Decided May 1, 2017No. Docket No. 22750-09Published

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

  1. Maxwell v. CommissionerUnited States Tax Court · 1986
  2. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
  3. White v. CommissionerUnited States Tax Court · 1990
  4. Crowell v. CommissionerUnited States Tax Court · 1994
  5. Roberts v. CommissionerUnited States Tax Court · 1990

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