Legal Opinion
McKnight v. Commissioner
Court of Appeals for the Fifth Circuit
Decided November 22, 1993No. 92-5150PublishedCited by 37 opinions
1Opinion of the Court
KING, Circuit Judge:
Sam A. McKnight and Ann V. McKnight appeal the decision of the United States Tax Court upholding its jurisdiction over the deficiency determination with respect to which the Commissioner did not use unified partnership-level audit procedures. Because we agree with the tax court that the taxpayers’ partnership qualified for the small partnership exemption to the unified procedures under I.R.C. § 6231(a)(1)(B), we affirm.
I. PROCEDURAL BACKGROUND
The McKnights filed a petition in the United States Tax Court seeking redetermination of a deficiency for $55,906 in income tax for…
2Cases cited12 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Batterton v. FrancisSupreme Court of the United States · 1977
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
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3Cited by37 opinions
- Edge Petroleum Operating Co. v. GPR Holdings, L.L.C.Court of Appeals for the Fifth Circuit · 2007
- Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
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