Maxwell v. Commissioner
United States Tax Court
Ps, Larry and Vickey, are partners in VIMAS, LTD., a limited partnership of more than 10 partners formed after Sept. 3, 1982. Larry is the general partner and the tax matters partner of VIMAS whose taxable year ends Dec. 31. R gave notice of the beginning of an administrative proceeding to audit VIMAS' 1982 partnership information return.
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Ps, Larry and Vickey, are partners in VIMAS, LTD., a limited partnership of more than 10 partners formed after Sept. 3, 1982. Larry is the general partner and the tax matters partner of VIMAS whose taxable year ends Dec. 31. R gave notice of the beginning of an administrative proceeding to audit VIMAS' 1982 partnership information return. On Apr. 25, 1985, R mailed Ps a statutory notice determining deficiencies for 1979, 1980, 1981, and 1982. In his notice for 1982, R disallowed Ps' claimed distributive shares of VIMAS' loss and investment tax credit, determined an addition to tax pursuant to…
1Opinion of the Court
OPINION
WILLIAMS, Judge:
Respondent has filed a motion to strike certain items at issue in this case from the petition for lack of jurisdiction. This Court must decide whether we have jurisdiction over the portion of the deficiencies and the additions to tax determined by respondent for petitioners’ 1979, 1980, 1981, and 1982 taxable years that arise out of certain adjustments of partnership items of income, deduction, or credit for the partnership taxable year ended December 31, 1982.
All of the facts have been stipulated and are so found. Petitioners are husband and wife who resided at…
2Cases cited1 opinion
- Southern v. CommissionerUnited States Tax Court · 1986
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