Hoffman v. Comm'r
United States Tax Court
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
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Reis v. CommissionerUnited States Tax Court · 1942
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