Barbados 6, Ltd. v. Commissioner
United States Tax Court
Held, Tax Court has jurisdiction where tax matters partner, which also satisfied all requirements as notice partner, timely filed petition as notice partner within 60 days after 90-day period given to tax matters partner, pursuant to sec. 6226(b), I.R.C. of 1954, as amended.
1Opinion of the Court
Barbados #6 Ltd., a Partnership, Bajan Services, Inc., Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent; Barbados #5 Ltd., a Partnership, Bajan Services, Inc., Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent 1
Barbados #6, Ltd. v. Commissioner
Docket Nos. 33764-84, 33878-84
United States Tax Court
85 T.C. 900; 1985 U.S. Tax Ct. LEXIS 11; 85 T.C. No. 53;
December 10, 1985, Filed
Held, Tax Court has jurisdiction where tax matters partner, which also satisfied all requirements as notice partner, timely filed petition as notice partner…
Also in this document: Dissent · Sterrett; Dissent · Hamblen.
2Cases cited8 opinions
- Pyo v. CommissionerUnited States Tax Court · 1984
- United States v. MinkerSupreme Court of the United States · 1956
- Barbados 6, Ltd. v. CommissionerUnited States Tax Court · 1985
- Robert Sheldon Pike and Ryk Henry Brouwer v. United StatesCourt of Appeals for the Ninth Circuit · 1965
- Derksen v. CommissionerUnited States Tax Court · 1985
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