Legal Opinion

Hoffman v. Comm'r

United States Tax Court

Decided September 24, 2002No. 16028-99LPublished

On Sept. 10, 1991, Ps timely filed a joint 1990 Federal income tax return on which they reported that they: (1) Held a general partner interest in one partnership and limited partner interests in five partnerships and (2) did not under sec. 469, I.R.C., materially participate in any of the partnerships. On Sept. 8, 1997, Ps filed an amended return for 1990 reporting additional income and remitting the tax due on that additional income.

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On Sept. 10, 1991, Ps timely filed a joint 1990 Federal income tax return on which they reported that they: (1) Held a general partner interest in one partnership and limited partner interests in five partnerships and (2) did not under sec. 469, I.R.C., materially participate in any of the partnerships. On Sept. 8, 1997, Ps filed an amended return for 1990 reporting additional income and remitting the tax due on that additional income. On Nov. 6, 1997, R assessed the additional tax liability reported on the amended return and assessed other amounts for a penalty and interest on that…

1Opinion of the Court

PETER M. AND SUSAN L. HOFFMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hoffman v. Comm'r

No. 16028-99L

United States Tax Court

119 T.C. 140; 2002 U.S. Tax Ct. LEXIS 44; 119 T.C. No. 7;

September 24, 2002, Filed

Judgment entered for petitioners.

On Sept. 10, 1991, Ps timely filed a joint 1990 Federal income

tax return on which they reported that they: (1) Held a general

partner interest in one partnership and limited partner

interests in five partnerships and (2) did not under sec. 469,

I.R.C., materially participate in any of the partnerships. On

Sept. 8, 1997, Ps filed an amended…

2Cases cited35 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  4. Brannen v. CommissionerUnited States Tax Court · 1982
  5. Reis v. CommissionerUnited States Tax Court · 1942

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