Spencer Medical Associates. v. Commissioner

Affirmed in part and dismissed in part by published opinion. Judge MOTZ wrote the opinion, in which Judge WIDENER and Judge HOWARD joined.

DIANA GRIBBON MOTZ, Circuit Judge:

Spencer Medical Associates (SMA) appeals from a decision of the United States Tax Court sustaining an adjustment assessed by the Internal Revenue Service (IRS) to the ordinary income reported on SMA’s 1990 partnership tax return, and from an order of the tax court denying a motion for reconsideration of the tax court’s findings and opinion. Because SMA did not timely file a notice of appeal from the tax court’s decision, we…