Legal Opinion

AHG Investments, LLC, Alan Ginsburg, A Partner Other Than the Tax Matters Partner v. Commissioner

United States Tax Court

Decided March 14, 2013No. 3745-09Published

1Opinion of the Court

140 T.C. No. 7

UNITED STATES TAX COURT AHG INVESTMENTS, LLC, ALAN GINSBURG, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3745-09. Filed March 14, 2013. R issued a notice of final partnership administrative adjustment (FPAA) determining adjustments to income on multiple grounds. The FPAA also determined an I.R.C. sec. 6662 40% gross valuation misstatement penalty, as well as other penalties. P conceded the adjustments to income on grounds other than valuation or basis in an attempt to avoid the gross valuation misstatement…

2Cases cited26 opinions

  1. Vasquez v. HillerySupreme Court of the United States · 1986
  2. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  3. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  4. Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
  5. Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988

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