Legal Opinion

Fein v. Commissioner

United States Tax Court

Decided August 4, 1994No. Docket No. 12905-92Unpublished

R issued a notice of deficiency based in part upon the disallowance of certain partnership loss deductions that were claimed by P for the tax years 1983, 1984, 1985, and 1986. P asserts that the assessment of tax attributable to those partnership items is barred by the statute of limitations, the discharge of P's liabilities in a bankruptcy proceeding, and the doctrine of laches.

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R issued a notice of deficiency based in part upon the disallowance of certain partnership loss deductions that were claimed by P for the tax years 1983, 1984, 1985, and 1986. P asserts that the assessment of tax attributable to those partnership items is barred by the statute of limitations, the discharge of P's liabilities in a bankruptcy proceeding, and the doctrine of laches. P further asserts that R's determination with respect to 1984 was not supported by sufficient evidence. 1. Held: Although R's statutory notice was issued after the normal 3-year limitation period had expired, the…

1Opinion of the Court

BRUCE F. FEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Fein v. Commissioner

Docket No. 12905-92

United States Tax Court

T.C. Memo 1994-370; 1994 Tax Ct. Memo LEXIS 379; 68 T.C.M. (CCH) 322;

August 4, 1994, Filed

Decision will be entered under Rule 155.

R issued a notice of deficiency based in part upon the disallowance of certain partnership loss deductions that were claimed by P for the tax years 1983, 1984, 1985, and 1986. P asserts that the assessment of tax attributable to those partnership items is barred by the statute of limitations, the discharge of P's liabilities in a…

2Cases cited10 opinions

  1. Foster v. Comm'rUnited States Tax Court · 1983
  2. Adler v. CommissionerUnited States Tax Court · 1985
  3. Neilson v. CommissionerUnited States Tax Court · 1990
  4. Graham v. CommissionerUnited States Tax Court · 1980
  5. Shriver v. CommissionerUnited States Tax Court · 1985

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