Modern Computer Games, Inc. v. Commissioner
United States Tax Court
P petitioned this Court as tax matters person (TMP) of Games, an S corporation, and moved for summary judgment on the ground that the notice of final S corporation administrative adjustment (FSAA) was mailed by R after the expiration of the statutory period of limitations. Games had never formally designated a tax matters person.
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P petitioned this Court as tax matters person (TMP) of Games, an S corporation, and moved for summary judgment on the ground that the notice of final S corporation administrative adjustment (FSAA) was mailed by R after the expiration of the statutory period of limitations. Games had never formally designated a tax matters person. Prior to the expiration of the limitations period and to the mailing of the FSAA, a consent agreement to extend the limitations period was executed by shareholder L, as TMP. L held the largest profits interest in Games. No person had been designated TMP by Games.…
1Opinion of the Court
Modern Computer Games, Inc., Carl D. Rader, Tax Matters Person, Petitioner v. Commissioner of Internal Revenue, Respondent
Modern Computer Games, Inc. v. Commissioner
Docket No. 1866-89
United States Tax Court
96 T.C. 839; 1991 U.S. Tax Ct. LEXIS 54; 96 T.C. No. 40;
June 20, 1991, Filed
An order will be issued denying the petitioner's motion for summary judgment.
P petitioned this Court as tax matters person (TMP) of Games, an S corporation, and moved for summary judgment on the ground that the notice of final S corporation administrative adjustment (FSAA) was mailed by R after the expiration of the…
2Cases cited5 opinions
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Chomp Assoc. v. CommissionerUnited States Tax Court · 1988
- Gold-N-Travel, Inc. v. CommissionerUnited States Tax Court · 1989
- Modern Computer Games, Inc. v. CommissionerUnited States Tax Court · 1991
- Modern Computer Games, Inc. v. CommissionerUnited States Tax Court · 1989