Brookes v. Commissioner
United States Tax Court
Ps were partners in a partnership that was the subject of a partnership proceeding. R mailed a notice of final partnership administrative adjustment (FPAA) for taxable years 1983 and 1984 to the tax matters partner (TMP). The TMP filed a petition, and Ps filed a motion to participate in the partnership proceeding, which this Court granted. The TMP settled the partnership case and certified that no party objected to the settlement.
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Ps were partners in a partnership that was the subject of a partnership proceeding. R mailed a notice of final partnership administrative adjustment (FPAA) for taxable years 1983 and 1984 to the tax matters partner (TMP). The TMP filed a petition, and Ps filed a motion to participate in the partnership proceeding, which this Court granted. The TMP settled the partnership case and certified that no party objected to the settlement. Ps did not receive notice of the settlement before the decision was entered by this Court but received notice of the decision 4 days after it was entered. Ps object…
1Opinion of the Court
OPINION
Gerber, Judge:
Respondent issued a notice of deficiency for petitioners’ 1980 and 1983 tax years, determining additions to tax attributable to petitioners’ partnership interest in Barrister Equipment Associates Series 122, a limited partnership (Barrister). The notice of deficiency was issued following the conclusion of a partnership proceeding involving Barrister’s 1983 and 1984 taxable years. In the parlance of partnership proceedings, additions to tax are described as affected items and come into play following the completion of the partnership proceeding. In response to the affected…
2Cases cited21 opinions
- Brinkerhoff-Faris Trust & Savings Co. v. HillSupreme Court of the United States · 1930
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Pyo v. CommissionerUnited States Tax Court · 1984
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
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3Cited by23 opinions
- Abel Kaplan and Mary Lou Kaplan v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Stewart v. Comm'rUnited States Tax Court · 2006
- Estate of Quick v. CommissionerUnited States Tax Court · 1998
- Asa Investerings P'Ship v. Comm'rUnited States Tax Court · 2002
- Bartimmo v. United StatesDistrict Court, S.D. Texas · 2007
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