Boyd v. Commissioner
United States Tax Court
R issued two notices of deficiency for Ps' 1983 tax year. R did not issue the first notice of deficiency within the time allowed by sec. 6501, I.R.C. R later conducted a Tefra partnership audit of a partnership in which Ps had invested in 1983. R issued a second notice of deficiency to Ps as a result of that audit.
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R issued two notices of deficiency for Ps' 1983 tax year. R did not issue the first notice of deficiency within the time allowed by sec. 6501, I.R.C. R later conducted a Tefra partnership audit of a partnership in which Ps had invested in 1983. R issued a second notice of deficiency to Ps as a result of that audit. Ps contend that issuance of the second notice of deficiency is barred by: (1) The general statute of limitations, sec. 6501, I.R.C.; (2) the limitation on issuance of two notices of deficiency to a taxpayer for 1 year, sec. 6212(c), I.R.C.; and (3) res judicata. Held, issuance of…
1Opinion of the Court
Lee C. and Barbara Kingan Boyd, Petitioners v. Commissioner of Internal Revenue, Respondent
Boyd v. Commissioner
Docket No. 20302-91
United States Tax Court
101 T.C. 365; 1993 U.S. Tax Ct. LEXIS 66; 101 T.C. No. 25;
November 1, 1993, Filed
Decision will be entered for respondent.
R issued two notices of deficiency for Ps' 1983 tax year. R did not issue the first notice of deficiency within the time allowed by sec. 6501, I.R.C. R later conducted a Tefra partnership audit of a partnership in which Ps had invested in 1983. R issued a second notice of deficiency to Ps as a result of that audit. Ps…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Patin v. CommissionerUnited States Tax Court · 1987
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
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