Digby v. Commissioner
United States Tax Court
R's agent (A) examined P's 1987 income tax return and after review of P's records allowed a loss from a related pass-through entity. The overall examination resulted in a deficiency, and P executed a Form 870 agreeing to assessment. P filed a 1988 return and thereafter filed an amended 1988 return, which claimed additional loss from the same related entity.
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R's agent (A) examined P's 1987 income tax return and after review of P's records allowed a loss from a related pass-through entity. The overall examination resulted in a deficiency, and P executed a Form 870 agreeing to assessment. P filed a 1988 return and thereafter filed an amended 1988 return, which claimed additional loss from the same related entity. R's agent (B) in the conduct of a 1988 examination inspected the records relating to the loss and determined that P had inadequate basis to claim a loss for 1988 and 1987. The same records would be considered or inspected to determine…
1Opinion of the Court
Donald R. Digby and Lydia Digby, Petitioners v. Commissioner of Internal Revenue, Respondent
Digby v. Commissioner
Docket Nos. 1352-92, 26770-92
United States Tax Court
103 T.C. 441; 1994 U.S. Tax Ct. LEXIS 66; 103 T.C. No. 24;
September 7, 1994, Filed
Decisions will be entered under Rule 155.
R's agent (A) examined P's 1987 income tax return and after review of P's records allowed a loss from a related pass-through entity. The overall examination resulted in a deficiency, and P executed a Form 870 agreeing to assessment. P filed a 1988 return and thereafter filed an amended 1988 return, which…
2Cases cited19 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- United States v. PowellSupreme Court of the United States · 1964
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- John Geurkink and Catherine Geurkink v. United StatesCourt of Appeals for the Seventh Circuit · 1965
- Collins v. CommissionerUnited States Tax Court · 1974
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