Home of Faith v. Commissioner

SEYMOUR, Chief Judge.

Home of Faith, an S corporation, and one of its shareholders appeal a Tax Court determination that the court had jurisdiction to redetermine adjustments made by the IRS to Home of Faith’s corporate returns using entity-level audit and litigation procedures. Shareholders in S corporations generally are required to follow the entity-level audit and litigation procedures which partners in partnerships must follow when challenging IRS adjustments to the entity’s tax return. We must decide in this case whether Congress intended to exempt from those procedures S corporations…