Legal Opinion

Adkison v. Comm'r

United States Tax Court

Decided October 16, 2007No. 2532-06Published

R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court's jurisdiction to redetermine the deficiency and to decide P's claim for relief under sec. 6015(c), I.R.C.

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R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court's jurisdiction to redetermine the deficiency and to decide P's claim for relief under sec. 6015(c), I.R.C. R moved to dismiss for lack of jurisdiction on the grounds (1) the notice of deficiency is invalid because the underlying adjustments constitute "partnership items" that are the subject of an ongoing partnership-level proceeding in Federal District Court, and (2) P's claim for relief under sec. 6015(c), I.R.C., constitutes an "affected item" that can be reviewed only after the partnership-level…

1Opinion of the Court

PETER D. ADKISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Adkison v. Comm'r

No. 2532-06

United States Tax Court

129 T.C. 97; 2007 U.S. Tax Ct. LEXIS 32; 129 T.C. No. 13;

October 16, 2007, Filed

R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court's jurisdiction to redetermine the deficiency and to decide P's claim for relief under sec. 6015(c), I.R.C. R moved to dismiss for lack of jurisdiction on the grounds (1) the notice of deficiency is invalid because the underlying adjustments constitute "partnership items" that are the subject of an…

2Cases cited16 opinions

  1. BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
  2. Maxwell v. CommissionerUnited States Tax Court · 1986
  3. Cheshire v. CommissionerUnited States Tax Court · 2000
  4. Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
  5. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987

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