Corson v. Comm'r
United States Tax Court
P was an investor in a partnership involved in tax shelter litigation in this Court. In 1985, P entered into settlement agreements with R, pursuant to which P could not deduct losses in excess of payments he had made to or on behalf of the partnership for taxable years before 1980 or after 1982. In 1999, after the partnership litigation concluded, R assessed additional income tax and accrued interest for P's taxable year 1983 attributable to P's involvement in the…
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P was an investor in a partnership involved in tax shelter litigation in this Court. In 1985, P entered into settlement agreements with R, pursuant to which P could not deduct losses in excess of payments he had made to or on behalf of the partnership for taxable years before 1980 or after 1982. In 1999, after the partnership litigation concluded, R assessed additional income tax and accrued interest for P's taxable year 1983 attributable to P's involvement in the partnership. P filed a claim for abatement of the interest. During P's correspondence conference with R, P provided to R a copy of…
1Opinion of the Court
THOMAS CORSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Corson v. Comm'r
No. 1025-03
United States Tax Court
123 T.C. 202; 2004 U.S. Tax Ct. LEXIS 35; 123 T.C. No. 10;
August 11, 2004, Filed
Corson v. Commissioner, 114 T.C. 354, 2000 U.S. Tax Ct. LEXIS 30 (2000)
Decision was entered for respondent.
P was an investor in a partnership involved in tax shelter
litigation in this Court. In 1985, P entered into settlement
agreements with R, pursuant to which P could not deduct losses
in excess of payments he had made to or on behalf of the
partnership for taxable years before 1980 or after…
2Cases cited14 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Clair S. Huffman v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
- Minahan v. CommissionerUnited States Tax Court · 1987
- Sokol v. CommissionerUnited States Tax Court · 1989
- Krause v. CommissionerUnited States Tax Court · 1992
9 more not listed; retrieve them via the Exa API.