Miller v. Commissioner
United States Tax Court
In 1983, Ps invested in Encore Leasing Corp. (Encore), through Alamo East Enterprises (Alamo East), an investment conduit. With respect to their investment in Encore through Alamo East, Ps claimed tax credits for taxable years 1980, 1981, 1983, and 1984. R mailed a notice of final partnership administrative adjustment (FPAA) to a partner of Alamo East with respect to Alamo East's 1983 tax return.
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In 1983, Ps invested in Encore Leasing Corp. (Encore), through Alamo East Enterprises (Alamo East), an investment conduit. With respect to their investment in Encore through Alamo East, Ps claimed tax credits for taxable years 1980, 1981, 1983, and 1984. R mailed a notice of final partnership administrative adjustment (FPAA) to a partner of Alamo East with respect to Alamo East's 1983 tax return. Alamo East filed a petition for readjustment of final partnership administrative adjustment with the U.S. District Court for the Northern District of California. On July 20, 1988, the petition was…
1Opinion of the Court
Glenn E. Miller and Sharon A. Miller, Petitioners v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket No. 24835-89
United States Tax Court
104 T.C. 378; 1995 U.S. Tax Ct. LEXIS 17; 104 T.C. No. 18;
March 29, 1995, Filed
An order will be issued denying petitioners' motion for summary judgment.
In 1983, Ps invested in Encore Leasing Corp. (Encore), through Alamo East Enterprises (Alamo East), an investment conduit. With respect to their investment in Encore through Alamo East, Ps claimed tax credits for taxable years 1980, 1981, 1983, and 1984. R mailed a notice of final…
2Cases cited11 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Naftel v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Rybak v. CommissionerUnited States Tax Court · 1988
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
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