Genesis Oil & Gas, Ltd. v. Commissioner
United States Tax Court
R moved to dismiss this partnership action for lack of jurisdiction on the ground that the petition was not timely filed by the TMP. P moved to dismiss on the ground that the FPAA was issued beyond the statute of limitations period. Held, the timeliness of the FPAA is not relevant to the jurisdiction of the Court under sec. 6226. R's motion to dismiss will be granted.
1Opinion of the Court
OPINION
GERBER, Judge:
This case was assigned to Special Trial Judge Larry L. Nameroff pursuant to section 7443A(b) of the Code1 and Rule 180 et seq. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
NAMEROFF, Special Trial Judge:
Petitioner filed a petition with this Court on June 23, 1987, seeking a redetermination of the adjustments made by respondent in a Notice of Final Partnership Administrative Adjustment (FPAA) for the taxable year ending December 31, 1982. On November 3, 1988, respondent filed a motion to…
2Cases cited8 opinions
- Abeles v. CommissionerUnited States Tax Court · 1988
- Robinson v. CommissionerUnited States Tax Court · 1972
- Brown v. CommissionerUnited States Tax Court · 1982
- Shelton v. CommissionerUnited States Tax Court · 1974
- Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
3 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Crowell v. CommissionerUnited States Tax Court · 1994
- Neely v. CommissionerUnited States Tax Court · 2000
- Block v. Comm'rUnited States Tax Court · 2003
- Costello v. United States GovernmentDistrict Court, C.D. California · 1991
- Central Valley AG Enterprises v. United StatesCourt of Appeals for the Ninth Circuit · 2008
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