Legal Opinion
Siben v. Commissioner
Court of Appeals for the Second Circuit
Decided April 18, 1991No. 1119, Docket 90-4128PublishedCited by 64 opinions
1Opinion of the Court
FEINBERG, Circuit Judge:
Petitioners appeal from an order of the United States Tax Court denying their motion for summary judgment, but certifying the case for interlocutory appeal pursuant to 26 U.S.C. § 7482(a)(2). This court granted leave to appeal in October 1990. The sole issue on appeal is whether the statute of limitations for assessing additional tax against an individual partner based on adjustments to partnership items should be measured from the date the partnership return was filed or the date the income tax *1035return of the individual partner was filed. The Tax Court held that the…
2Cases cited12 opinions
- Russello v. United StatesSupreme Court of the United States · 1983
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Seatrain Shipbuilding Corp. v. Shell Oil Co.Supreme Court of the United States · 1980
7 more not listed; retrieve them via the Exa API.
3Cited by64 opinions
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Lardas v. CommissionerUnited States Tax Court · 1992
- Stahl v. CommissionerUnited States Tax Court · 1991
- Robinson v. Comm'rUnited States Tax Court · 2001
- Jon J. Paulson Gloria J. Paulson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1993
59 more not listed; retrieve them via the Exa API.