Hang v. Commissioner
United States Tax Court
Respondent issued notices of Final S Corporation Administrative Adjustment (FSAA) for 1984 and 1985 in which he reallocated income of an S corporation from the shareholders of record to H, who is not a shareholder of record.
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Respondent issued notices of Final S Corporation Administrative Adjustment (FSAA) for 1984 and 1985 in which he reallocated income of an S corporation from the shareholders of record to H, who is not a shareholder of record. Petitioners moved to dismiss and/or for partial judgment on the pleadings with respect to the reallocations for 1984 and 1985. Held, the reallocation of a subchapter S item from shareholders of record to a taxpayer who is not a shareholder of record is not within the scope of judicial review in an S corporation proceeding.
1Opinion of the Court
William M. Hang and Deborah S. Hang and Davidan Orthodontic Lab, Inc., David R. Hang, Tax Matters Person, Deborah S. Hang, Guardian and Daniel W. Hang, a Person Other Than the Tax Matters Person, Petitioners v. Commissioner of Internal Revenue, Respondent
Hang v. Commissioner
Docket No. 9367-89
United States Tax Court
95 T.C. 74; 1990 U.S. Tax Ct. LEXIS 69; 95 T.C. No. 6;
July 18, 1990, Filed
Respondent issued notices of Final S Corporation Administrative Adjustment (FSAA) for 1984 and 1985 in which he reallocated income of an S corporation from the shareholders of record to H, who is not a…
2Cases cited11 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Albert Schoenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Hook v. CommissionerUnited States Tax Court · 1972
- Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1947
- Hang v. CommissionerUnited States Tax Court · 1990
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