Estate of Magarian v. Commissioner
United States Tax Court
R disallowed deductions Ps claimed with respect to a partnership on their Federal tax return for the taxable year 1981. Ps and R subsequently entered into a closing agreement pursuant to I.R.C. section 7121 respecting the disputed deductions.
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R disallowed deductions Ps claimed with respect to a partnership on their Federal tax return for the taxable year 1981. Ps and R subsequently entered into a closing agreement pursuant to I.R.C. section 7121 respecting the disputed deductions. R later issued to Ps a notice of deficiency determining additions to tax and increased interest for the taxable year 1981. Ps assert that the closing agreement bars R from determining additions to tax and increased interest for that year. Held, this Court lacks jurisdiction to redetermine Ps' liability for increased interest pursuant to I.R.C. section…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
Respondent determined additions to petitioners’ Federal income tax and increased interest for the taxable year 1981 as follows:
Sec. 6653(a)(1) Sec. 6653(a)(2) $324 1
Sec. 6659 $1,944
Sec. 6621(c)
2
150 percent of the interest due on $6,480.
2120 percent of the interest due on $6,480.
(Section references are to the Internal Revenue Code as amended and in effect for the year at issue.)
The sole issue to be decided is whether a closing agreement executed by the parties with respect to the taxable year 1981 bars respondent from determining additions to tax for 1981. If we decide…
2Cases cited5 opinions
- Zaentz v. CommissionerUnited States Tax Court · 1988
- White v. CommissionerUnited States Tax Court · 1990
- Arthur C. Ewing A/K/A A. Clifford Ewing Maxine H. Ewing v. United StatesCourt of Appeals for the Fourth Circuit · 1990
- Odend'Hal v. CommissionerUnited States Tax Court · 1990
- William L. Smith and Jacquelyn Smith v. United StatesCourt of Appeals for the Fifth Circuit · 1988
3Cited by21 opinions
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- DeSantis v. United StatesDistrict Court, S.D. New York · 1992
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- H Graphics/Access, Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
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