Rosefsky v. Commissioner
United States Tax Court
A partnership had income in 1970 from the proceeds of a condemnation award. The statute of limitations was still open with regard to any deficiency related to such income because it had been extended by a sec. 1033 election made by the partnership.
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A partnership had income in 1970 from the proceeds of a condemnation award. The statute of limitations was still open with regard to any deficiency related to such income because it had been extended by a sec. 1033 election made by the partnership. The partners claimed that they were protected by the statute of limitations for their taxable year 1970 because they as individuals had not made a sec. 1033 election and had not, therefore, extended the statute with respect to themselves as individuals. Held: The deficiency was proposed against petitioners with respect to the partnership sec. 1033…
1Opinion of the Court
Alec Rosefsky and Edith Rosefsky, Petitioners v. Commissioner of Internal Revenue, Respondent; Joseph A. D'Esti and Helen T. D'Esti, Petitioners v. Commissioner of Internal Revenue, Respondent
Rosefsky v. Commissioner
Docket Nos. 1022-76, 1023-76
United States Tax Court
70 T.C. 909; 1978 U.S. Tax Ct. LEXIS 60;
September 12, 1978, Filed
Decisions will be entered for the respondent.
A partnership had income in 1970 from the proceeds of a condemnation award. The statute of limitations was still open with regard to any deficiency related to such income because it had been extended by a sec. 1033…
2Cases cited4 opinions
- Demirjian v. CommissionerCourt of Appeals for the Third Circuit · 1972
- William Q. Boyce, Individually and as of the Will and Estate of Ida Mae Boyce, Deceased v. The United StatesUnited States Court of Claims · 1968
- American Natural Gas Co. v. United StatesUnited States Court of Claims · 1960
- Rosefsky v. CommissionerUnited States Tax Court · 1978