Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided December 11, 1997No. Tax Ct. Dkt. No. 13623-96Unpublished

R moved for partial summary judgment on an issue informally raised by P during an IRS Appeals Office conference as to whether the period of limitations for assessment had expired as a result of R's alleged failure to honor an election by P's partnership for treatment under the unified audit provisions of secs. 6221 through 6233, I.R.C.

Read the full summary

R moved for partial summary judgment on an issue informally raised by P during an IRS Appeals Office conference as to whether the period of limitations for assessment had expired as a result of R's alleged failure to honor an election by P's partnership for treatment under the unified audit provisions of secs. 6221 through 6233, I.R.C. R also moved to impose sanctions under Rule 104(c), Tax Court Rules of Practice and Procedure, including dismissal, for P's ongoing noncompliance with a discovery order of the Court. P filed oppositions to both of R's motions. 1. HELD: R's motion for partial…

1Opinion of the Court

LARRY BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brown v. Commissioner

Tax Ct. Dkt. No. 13623-96

United States Tax Court

T.C. Memo 1997-548; 1997 Tax Ct. Memo LEXIS 632; 74 T.C.M. (CCH) 1363;

December 11, 1997, Filed

An appropriate order and order of dismissal and decision will be entered.

R moved for partial summary judgment on an issue informally raised by P during an IRS Appeals Office conference as to whether the period of limitations for assessment had expired as a result of R's alleged failure to honor an election by P's partnership for treatment under the unified audit…

2Cases cited24 opinions

  1. National Hockey League v. Metropolitan Hockey Club, Inc.Supreme Court of the United States · 1976
  2. Societe Internationale Pour Participations Industrielles Et Commerciales, S. A. v. RogersSupreme Court of the United States · 1958
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API