Legal Opinion

1983 Western Reserve Oil & Gas Co. v. Commissioner

United States Tax Court

Decided July 12, 1990No. Docket Nos. 17301-87, 17441-87, 17703-87, 18039-87, 18596-87, 18853-87, 27014-87Published

WROG and 1983 WROG are limited partnerships. The tax matters partner, P, disappeared in 1985 when a warrant was issued for his arrest. In February 1986, the two limited partnerships were placed in receivership and S was appointed receiver pendente lite by the U.S. District Court. S was not a partner in WROG or 1983 WROG.

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WROG and 1983 WROG are limited partnerships. The tax matters partner, P, disappeared in 1985 when a warrant was issued for his arrest. In February 1986, the two limited partnerships were placed in receivership and S was appointed receiver pendente lite by the U.S. District Court. S was not a partner in WROG or 1983 WROG. Creditors of WROG and 1983 WROG instituted involuntary bankruptcy proceedings against the two partnerships in May 1986. In September 1987, the receivership was terminated and the proceedings were referred to the bankruptcy court by the U.S. District Court. Notices of final…

1Opinion of the Court

1983 Western Reserve Oil & Gas Co., Ltd., Richard G. Shaffer, Receiver Pendente Lite, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

1983 Western Reserve Oil & Gas Co. v. Commissioner

Docket Nos. 17301-87, 17441-87, 17703-87, 18039-87, 18596-87, 18853-87, 27014-87

United States Tax Court

95 T.C. 51; 1990 U.S. Tax Ct. LEXIS 68; 95 T.C. No. 4;

July 12, 1990, Filed

Orders granting respondent's motions to dismiss for lack of jurisdiction will be entered in docket Nos. 17301-87, 17703-87, 18039-87, 18596-87, and 27014-87.

Orders denying respondent's motions to dismiss for lack of…

2Cases cited23 opinions

  1. Burns, Stix Friedman & Co. v. CommissionerUnited States Tax Court · 1971
  2. Estate of Young v. CommissionerUnited States Tax Court · 1983
  3. Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
  4. Medeiros v. CommissionerUnited States Tax Court · 1981
  5. Liberty Nat. Bank of Roanoke, Va. v. BearSupreme Court of the United States · 1928

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