Fein v. Commissioner
United States Tax Court
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
- Foster v. Comm'rUnited States Tax Court · 1983
- Adler v. CommissionerUnited States Tax Court · 1985
- Neilson v. CommissionerUnited States Tax Court · 1990
- Graham v. CommissionerUnited States Tax Court · 1980
- Shriver v. CommissionerUnited States Tax Court · 1985
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