Legal Opinion

Bedrosian v. Comm'r

United States Tax Court

Decided August 13, 2014No. Docket No. 12341-05Published

Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, 96 Stat. 324. R issued an FPAA with respect to the partnership; R included with the FPAA a notice under I.R.C. sec. 6223(e), informing Ps of their right to opt out of the TEFRA proceeding. The FPAA was properly mailed, but Ps claim that they did not receive it within the time in which to file a timely petition.

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Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, 96 Stat. 324. R issued an FPAA with respect to the partnership; R included with the FPAA a notice under I.R.C. sec. 6223(e), informing Ps of their right to opt out of the TEFRA proceeding. The FPAA was properly mailed, but Ps claim that they did not receive it within the time in which to file a timely petition. Ps filed an untimely petition, which the Court dismissed; the Court of Appeals for the Ninth Circuit upheld the…

1Opinion of the Court

JOHN C. BEDROSIAN AND JUDITH D. BEDROSIAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bedrosian v. Comm'r

Docket No. 12341-05.

United States Tax Court

143 T.C. 83; 2014 U.S. Tax Ct. LEXIS 35; 143 T.C. No. 4;

August 13, 2014, Filed

Bedrosian v. Commissioner, 358 Fed. Appx. 868, 2009 U.S. App. LEXIS 26238 (9th Cir., 2009)

Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, 96 Stat. 324. R issued an FPAA with respect to the partnership; R included with the FPAA a notice…

Also in this document: Concurrence · Halpern; Concurrence · Goeke; Dissent.

2Cases cited69 opinions

  1. Connecticut National Bank v. GermainSupreme Court of the United States · 1992
  2. Taylor v. SturgellSupreme Court of the United States · 2008
  3. Arizona v. CaliforniaSupreme Court of the United States · 1983
  4. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

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