Curtis v. Commissioner
United States Tax Court
Petitioner, a California resident, held a 9.5-percent interest in a Florida limited partnership. In 1978, respondent inspected petitioner's 1976 return, and subsequently inspected the books of account of the limited partnership without notifying petitioner. Held, inspection of the books of account of the limited partnership does not constitute a second inspection of petitioner's books of account, and thus does not violate sec. 7605(b), I.R.C. 1954.
1Opinion of the Court
Leslie C. Curtis and Joan Curtis, Petitioners v. Commissioner of Internal Revenue, Respondent
Curtis v. Commissioner
Docket No. 12978-80
United States Tax Court
84 T.C. 1349; 1985 U.S. Tax Ct. LEXIS 65; 84 T.C. No. 74;
June 24, 1985. June 24, 1985, Filed
Decision will be entered under Rule 155.
Petitioner, a California resident, held a 9.5-percent interest in a Florida limited partnership. In 1978, respondent inspected petitioner's 1976 return, and subsequently inspected the books of account of the limited partnership without notifying petitioner. Held, inspection of the books of account of the…
2Cases cited19 opinions
- United States v. PowellSupreme Court of the United States · 1964
- Bellis v. United StatesSupreme Court of the United States · 1974
- United States v. BasyeSupreme Court of the United States · 1973
- Grant Foster and Foster Construction C.A., Intervenors-Appellants v. United StatesCourt of Appeals for the Second Circuit · 1959
- Benjamin v. CommissionerUnited States Tax Court · 1976
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