White v. Commissioner
United States Tax Court
After the partnership level proceeding was completed, R issued a notice of deficiency to Ps determining that Ps were liable for additional interest under I.R.C. sec. 6621(c) and additions to tax under I.R.C. secs. 6651(a)(1), 6653(a)(1), 6653(a)(2) and 6659. Ps timely filed a petition for redetermination of R's determinations.
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After the partnership level proceeding was completed, R issued a notice of deficiency to Ps determining that Ps were liable for additional interest under I.R.C. sec. 6621(c) and additions to tax under I.R.C. secs. 6651(a)(1), 6653(a)(1), 6653(a)(2) and 6659. Ps timely filed a petition for redetermination of R's determinations. R filed a motion to dismiss for lack of jurisdiction as to I.R.C. sec. 6621(c). Held, this Court does not have jurisdiction under I.R.C. section 6230(a)(2)(A)(i) to redetermine I.R.C. sec. 6621(c) interest because I.R.C. sec. 6621(c) interest is not a "deficiency"…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction as to section 6621(c). (Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1984 and all Rule references are to the Tax Court Rules of Practice and Procedure.) Section 7721(b) of the Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, 103 Stat. 2106, 2399, repealed section 6621(c) effective for returns with a due date (determined without regard to extensions) after December 31, 1989.)
On April 5, 1988, respondent issued a Notice…
2Cases cited4 opinions
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Saso v. CommissionerUnited States Tax Court · 1989
- COMMISSIONER OF INT. REVENUE v. Kilpatrick's EstateCourt of Appeals for the Sixth Circuit · 1944
- Transport Manufacturing & Equipment Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1970
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