Legal Opinion
John C. Bedrosian & Judith D. Bedrosian v. Commissioner
United States Tax Court
Decided August 13, 2014No. Docket 12341-05Unknown
1Opinion of the Court
JOHN C. BEDROSIAN AND JUDITH D. BEDROSIAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 12341–05. Filed August 13, 2014. Ps invested in a Son-of-BOSS transaction through a part- nership that was subject to the Tax Equity and Fiscal Respon- sibility Act of 1982 (TEFRA), Pub. L. No. 97–248, 96 Stat. 324. R issued an FPAA with respect to the partnership; R included with the FPAA a notice under I.R.C. sec. 6223(e), informing Ps of their right to opt out of the TEFRA pro- ceeding. The FPAA was properly mailed, but Ps claim that they did not receive it within the time in…
2Cases cited65 opinions
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Taylor v. SturgellSupreme Court of the United States · 2008
- Arizona v. CaliforniaSupreme Court of the United States · 1983
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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