Sparks v. Commissioner
United States Tax Court
Ps are partners in the Project Omega Limited Partnership (the partnership). A portion of the deficiency determined by R for Ps' taxable year 1982 arises from adjustments to partnership items of the partnership.
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Ps are partners in the Project Omega Limited Partnership (the partnership). A portion of the deficiency determined by R for Ps' taxable year 1982 arises from adjustments to partnership items of the partnership. The offering memorandum, the limited partnership agreement of the partnership, and other documents state that the partnership will be formed upon termination of the offering which occurred in December of 1982. As of Sept. 3, 1982, the partnership's escrow account held $ 24,000, representing 4 units of participation (of a total of 80 units to be sold), and the general partner had begun…
1Opinion of the Court
WILLIAMS, Judge:*
This case is before the Court on respondent’s motion to sever from the petition the adjustments relating to the Project Omega Limited Partnership that resulted in a portion of the deficiency determined by respondent in Federal income tax for petitioners’ taxable year 1982.
The Commissioner determined deficiencies in petitioners’ Federal income tax for the taxable years 1981 and 1982 and additions to tax as follows:1
Additions to tax
Year ended
Dec. 31— Deficiency Sec. 66511 Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1981 $46,707.84 $11,677 $2,832 50% of the interest due on…
2Cases cited8 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Dwinell's Central Neon v. Cosmopolitan Chinook HotelCourt of Appeals of Washington · 1978
- Hensel Phelps Constr. Co. v. CommissionerUnited States Tax Court · 1980
3 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Antonides v. CommissionerUnited States Tax Court · 1988
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Torres v. CommissionerUnited States Tax Court · 1987
- Crowell v. CommissionerUnited States Tax Court · 1994
- Stieha v. CommissionerUnited States Tax Court · 1987
37 more not listed; retrieve them via the Exa API.