Stieha v. Commissioner
United States Tax Court
Ps filed a motion to dismiss for lack of jurisdiction on Dec. 4, 1986, alleging that the notice of deficiency was invalid because R failed to comply with the partnership audit and litigation procedures. Sec. 6221 et seq., I.R.C. 1986. On Dec. 8, 1986, the Court filed its opinion in Sparks v. Commissioner, 87 T.C. 1279, which was dispositive of the issue presented in Ps' motion to dismiss.
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Ps filed a motion to dismiss for lack of jurisdiction on Dec. 4, 1986, alleging that the notice of deficiency was invalid because R failed to comply with the partnership audit and litigation procedures. Sec. 6221 et seq., I.R.C. 1986. On Dec. 8, 1986, the Court filed its opinion in Sparks v. Commissioner, 87 T.C. 1279, which was dispositive of the issue presented in Ps' motion to dismiss. On Jan. 12, 1987, R requested an extension of time for filing objections to Ps' motion because he had not received the motion in a timely manner and needed additional time to research the important legal…
1Opinion of the Court
OPINION
WILLIAMS, Judge-.
This case is before us on petitioners’ motion for litigation costs seeking $3,900 in attorneys’ fees. In his notice of deficiency dated August 13, 1986, the Commissioner determined deficiencies in petitioners’ Federal income tax for the taxable years 19791 and 1982 and an addition to tax for the taxable year 1982 as follows:
Sec. 6653(a)2
addition to tax Year Deficiency
0 1979 $420
$496.05 1982 9,921
The deficiencies were based entirely on the disallowance of petitioners’ distributive share of 1982 losses and investment tax credits from Missoula Water Works, Ltd. (MWW), a…
2Cases cited3 opinions
- Sher v. CommissionerUnited States Tax Court · 1987
- Weiss v. CommissionerUnited States Tax Court · 1987
- Sparks v. CommissionerUnited States Tax Court · 1986
3Cited by45 opinions
- Gantner v. CommissionerUnited States Tax Court · 1989
- Coastal Petroleum Refiners, Inc. v. CommissionerUnited States Tax Court · 1990
- Cassuto v. CommissionerUnited States Tax Court · 1989
- Weiss v. CommissionerUnited States Tax Court · 1987
- Price v. CommissionerUnited States Tax Court · 1994
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