Legal Opinion

Goettee v. Comm'r

United States Tax Court

Decided May 31, 2005No. 26591-96Published

Ps claimed investment credits and losses arising out of a partnership in which they held a limited interest. By notice of deficiency, R disallowed these claimed credits and losses. Ps accepted a settlement offer from R and paid all deficiencies and additions reflected in the entered decision. Ps requested abatement of interest on these amounts. R initially disallowed the abatement request in full, then later allowed partial abatement.

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Ps claimed investment credits and losses arising out of a partnership in which they held a limited interest. By notice of deficiency, R disallowed these claimed credits and losses. Ps accepted a settlement offer from R and paid all deficiencies and additions reflected in the entered decision. Ps requested abatement of interest on these amounts. R initially disallowed the abatement request in full, then later allowed partial abatement. Ps then paid the remaining assessed interest liabilities. Ps petitioned this Court to review R's disallowance of interest abatements. After R's concessions, we…

1Opinion of the Court

JOHN G. GOETTEE, JR. AND MARIAN GOETTEE, * Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Goettee v. Comm'r

No. 26591-96

United States Tax Court

124 T.C. 286; 2005 U.S. Tax Ct. LEXIS 18; 124 T.C. No. 17;

May 31, 2005., Filed

Goettee v. Commissioner, T.C. Memo 2004-9, 2004 Tax Ct. Memo LEXIS 9 (T.C., 2004)

Ps claimed investment credits and losses arising out of a

partnership in which they held a limited interest. By notice of

deficiency, R disallowed these claimed credits and losses. Ps

accepted a settlement offer from R and paid all deficiencies and

additions reflected in the entered…

2Cases cited10 opinions

  1. Minahan v. CommissionerUnited States Tax Court · 1987
  2. Fla. Country Clubs, Inc. v. Comm'rUnited States Tax Court · 2004
  3. Dixson Int'l Service Corp. v. CommissionerUnited States Tax Court · 1990
  4. Corson v. Comm'rUnited States Tax Court · 2004
  5. Hiep H. Dang Phuong My T. Chau v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2001

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