Abrams v. Commissioner
United States Tax Court
A pre-filing notification letter was sent by a District Director for respondent to each taxpayer who had invested in a certain tax shelter. The letter stated that the taxpayer's return would be reviewed and any deductions taken in regard to the shelter would be disallowed, with consideration given to the determination of appropriate "penalties."
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A pre-filing notification letter was sent by a District Director for respondent to each taxpayer who had invested in a certain tax shelter. The letter stated that the taxpayer's return would be reviewed and any deductions taken in regard to the shelter would be disallowed, with consideration given to the determination of appropriate "penalties." The taxpayers filed a consolidated petition with this Court on the ground that the pre-filing notification letter constitutes a notice of deficiency. Respondent filed a motion to dismiss for lack of jurisdiction. Held: The pre-filing notification…
1Opinion of the Court
OPINION
Dawson, Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction filed on April 4, 1985. Without a hearing, an order was entered on April 12, 1985, granting respondent’s motion. This order was vacated and set aside on April 16, 1985, and a hearing on the motion was held on May 22, 1985, at the motions session in Washington, D.C. The parties filed memoranda of points and authorities. After considering the memoranda and the arguments made by the parties at the hearing, the Court took respondent’s motion under advisement.
On November 2, 1984, the…
2Cases cited8 opinions
- Laing v. United StatesSupreme Court of the United States · 1976
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Foster v. Comm'rUnited States Tax Court · 1983
- Scar v. CommissionerUnited States Tax Court · 1983
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
3 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Richard L. Abrams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Clovis I v. CommissionerUnited States Tax Court · 1987
- Bourekis v. Comm'rUnited States Tax Court · 1998
- Kellogg v. CommissionerUnited States Tax Court · 1987
- Steven E. Donley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
35 more not listed; retrieve them via the Exa API.