Thompson v. Commissioner
United States Tax Court
On the basis of a final decision in a partnership-level proceeding for RJT Investments X, LLC, which had made all partnership allocations for its tax year ended Dec. 31, 2001, to P-H, R determined an income tax deficiency and an accuracy-related penalty for Ps' 2001 tax year. Immediately after issuing a notice of deficiency to Ps, R directly assessed the deficiency and penalty amounts determined in that notice.
Read the full summary
On the basis of a final decision in a partnership-level proceeding for RJT Investments X, LLC, which had made all partnership allocations for its tax year ended Dec. 31, 2001, to P-H, R determined an income tax deficiency and an accuracy-related penalty for Ps' 2001 tax year. Immediately after issuing a notice of deficiency to Ps, R directly assessed the deficiency and penalty amounts determined in that notice. R has since acknowledged errors in these deficiency and penalty amounts and has made corresponding assessment abatements. Nonetheless, R argues that the notice of deficiency is invalid…
1Opinion of the Court
OPINION
Wherry, Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. The case constitutes a partner-level action under the unified partnership audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (tefra), Pub. L. 97-248, sec. 402(a), 96 Stat. 324.1
Background
I. Partnership-Level Proceeding
Petitioner husband, Randall J. Thompson, engaged in a Son-of-BOSS (boss) market linked deposit transaction in 2001, seeking to offset approximately $21,500,000 in capital gains. To facilitate the BOSS transaction, petitioner husband…
2Cases cited55 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
- Montana v. United StatesSupreme Court of the United States · 1979
- United States v. CottonSupreme Court of the United States · 2002
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
50 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Rawls Trading, L.P. v. Comm'rUnited States Tax Court · 2012
- 6611, Ltd. v. Comm'rUnited States Tax Court · 2013
- Kenna Trading, LLC v. Comm'rUnited States Tax Court · 2014
- Sotiropoulos v. CommissionerUnited States Tax Court · 2014
- Kenna Trading, LLC, Jetstream Business Limited, Tax Matters Partner v. CommissionerUnited States Tax Court · 2014
13 more not listed; retrieve them via the Exa API.