Tallal v. Commissioner
United States Tax Court
Held, a timely signed consent extending the statute of limitations for assessment and collection of income tax for a year for which a joint return was filed is valid to extend the statute with respect to the husband who signed the consent, even though the statute of limitations barred the determination of a deficiency for that year against his ex-wife, who did not sign it.
1Opinion of the Court
OPINION
Scott, Judge:
This case is before the Court on a motion to dismiss filed by petitioners on March 20, 1981, which, by agreement of the parties, was argued and considered as a motion for summary judgment.
Respondent, by notice mailed to petitioners on July 11,1980, determined that there was a deficiency in the income tax of Joseph J. Tallal, Jr., and Pamela J. Tallal, for the taxable year ended December 31, 1976, in the amount of $26,474. The determination of deficiency was based entirely upon the disallowance of a loss claimed on petitioners’ return from a partnership interest in a…
2Cases cited5 opinions
- United States v. StewartSupreme Court of the United States · 1940
- Boulez v. CommissionerUnited States Tax Court · 1981
- Dolan v. CommissionerUnited States Tax Court · 1965
- Ekdahl v. CommissionerUnited States Board of Tax Appeals · 1930
- United States v. GayneCourt of Appeals for the Second Circuit · 1943
3Cited by50 opinions
- Kronish v. CommissionerUnited States Tax Court · 1988
- Piarulle v. Comm'rUnited States Tax Court · 1983
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- Grunwald v. CommissionerUnited States Tax Court · 1986
- Amesbury Apartments, Ltd. v. CommissionerUnited States Tax Court · 1990
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