Legal Opinion

508 Clinton St. Corp. v. Commissioner

United States Tax Court

Decided August 25, 1987No. Docket No. 5845-86Published

Respondent determined deficiencies in petitioner's personal holding company tax under sec. 541, I.R.C. 1954, for the fiscal years ended Sept. 30, 1979, and Sept. 30, 1982. Petitioner concedes that it is liable for the full amount of such deficiencies.

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Respondent determined deficiencies in petitioner's personal holding company tax under sec. 541, I.R.C. 1954, for the fiscal years ended Sept. 30, 1979, and Sept. 30, 1982. Petitioner concedes that it is liable for the full amount of such deficiencies. In its trial memorandum, however, petitioner asserts that respondent's denial of petitioner's request to abate the interest assessments attributable to such deficiencies violates the interest abatement provisions in sec. 6404(e), as enacted by the Tax Reform Act of 1986. Held, the Court lacks jurisdiction to address the interest abatement issue…

1Opinion of the Court

508 Clinton Street Corp., Petitioner v. Commissioner of Internal Revenue, Respondent

508 Clinton St. Corp. v. Commissioner

Docket No. 5845-86

United States Tax Court

89 T.C. 352; 1987 U.S. Tax Ct. LEXIS 121; 89 T.C. No. 31;

August 25, 1987. August 25, 1987, Filed

Respondent determined deficiencies in petitioner's personal holding company tax under sec. 541, I.R.C. 1954, for the fiscal years ended Sept. 30, 1979, and Sept. 30, 1982. Petitioner concedes that it is liable for the full amount of such deficiencies. In its trial memorandum, however, petitioner asserts that respondent's denial of…

2Cases cited22 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
  3. Breman v. CommissionerUnited States Tax Court · 1976
  4. LTV Corp. v. CommissionerUnited States Tax Court · 1975
  5. Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960

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