Gillilan v. Commissioner
United States Tax Court
P and H jointly owned an interest in a partnership. P and H signed a Form 870-L(AD), offering to settle partnership and affected items with R. Prior to R's signing the Form 870-L(AD), H filed a bankruptcy petition. P and H later signed a Form 870, consenting to the immediate assessment and collection of tax. R then assessed against P. R subsequently issued a deficiency notice to P and H for the tax previously assessed.
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P and H jointly owned an interest in a partnership. P and H signed a Form 870-L(AD), offering to settle partnership and affected items with R. Prior to R's signing the Form 870-L(AD), H filed a bankruptcy petition. P and H later signed a Form 870, consenting to the immediate assessment and collection of tax. R then assessed against P. R subsequently issued a deficiency notice to P and H for the tax previously assessed. R moves to dismiss for lack of jurisdiction on the ground that, due to the prior assessment, there was no deficiency determination and the deficiency notice therefore was…
1Opinion of the Court
NELDA J. GILLILAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gillilan v. Commissioner
Docket No. 20993-92
United States Tax Court
T.C. Memo 1993-366; 1993 Tax Ct. Memo LEXIS 374; 66 T.C.M. (CCH) 398;
August 18, 1993, Filed
P and H jointly owned an interest in a partnership. P and H signed a Form 870-L(AD), offering to settle partnership and affected items with R. Prior to R's signing the Form 870-L(AD), H filed a bankruptcy petition. P and H later signed a Form 870, consenting to the immediate assessment and collection of tax. R then assessed against P. R subsequently issued a…
2Cases cited3 opinions
- Kalb v. FeuersteinSupreme Court of the United States · 1940
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- Dubin v. CommissionerUnited States Tax Court · 1992
3Cited by9 opinions
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- Keener v. United StatesUnited States Court of Federal Claims · 2007
- Prati v. United StatesUnited States Court of Federal Claims · 2008
- Katz v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- Alpha I, L.P. ex rel. Sands v. United StatesUnited States Court of Federal Claims · 2009
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