Bradley v. Commissioner
United States Tax Court
Respondent moved to dismiss for lack of jurisdiction as to partnership items which had previously been disposed of in an administrative proceeding.
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Respondent moved to dismiss for lack of jurisdiction as to partnership items which had previously been disposed of in an administrative proceeding. Petitioner objects on the grounds (1) the reference to the deficiency in respect of the partnership items contained in the statutory notice is sufficient to confer jurisdiction of those items, (2) the notice of final partnership administrative adjustment (FPAA) was untimely because it was issued after the period of limitations had expired, and (3) the statutory notice was invalid because petitioner did not receive a notice of computational…
1Opinion of the Court
OPINION
TanNenwald, Judge:
This case is before us on respondent’s motion to dismiss for lack of jurisdiction insofar as the petition herein seeks to put partnership items in issue for 1982.
All of the relevant facts and documents have been stipulated and are so found.
Petitioner resided in California when he filed the petition in this case. He timely filed a Federal income tax return for the 1982 taxable year with the Internal Revenue Service Center, Fresno, California.
On October 27, 1982, a certificate of limited partnership creating Harvard Associates 82-1, a Limited Partnership (referred to as…
2Cases cited15 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Adler v. CommissionerUnited States Tax Court · 1985
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
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3Cited by32 opinions
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