Wise Guys Holdings, LLC v. Comm'r
United States Tax Court
R mailed to P, as W's tax matters partner (TMP), a notice of final partnership administrative adjustment (FPAA) for W's 2007 taxable year. Approximately nine months later, R (through an office different from the office that mailed the FPAA) mailed to P, as W's TMP, a second FPAA for W's 2007 taxable year. The first FPAA and the second FPAA are similar in content but are different in the contact information (and a few other minor items) shown on the face.
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R mailed to P, as W's tax matters partner (TMP), a notice of final partnership administrative adjustment (FPAA) for W's 2007 taxable year. Approximately nine months later, R (through an office different from the office that mailed the FPAA) mailed to P, as W's TMP, a second FPAA for W's 2007 taxable year. The first FPAA and the second FPAA are similar in content but are different in the contact information (and a few other minor items) shown on the face. P filed his petition in response to the second FPAA but after the statutory deadline for challenging the first FPAA had expired. Held: The…
1Opinion of the Court
WISE GUYS HOLDINGS, LLC, PETER J. FORSTER, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wise Guys Holdings, LLC v. Comm'r
Docket No. 6643-12.
United States Tax Court
140 T.C. 193; 2013 U.S. Tax Ct. LEXIS 9; 140 T.C. No. 8;
April 22, 2013, Filed
An appropriate order of dismissal will be entered.
R mailed to P, as W's tax matters partner (TMP), a notice of final partnership administrative adjustment (FPAA) for W's 2007 taxable year. Approximately nine months later, R (through an office different from the office that mailed the FPAA) mailed to P, as W's TMP, a second…
2Cases cited16 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Neilson v. CommissionerUnited States Tax Court · 1990
- Fehrs v. CommissionerUnited States Tax Court · 1975
- Barbados 6, Ltd. v. CommissionerUnited States Tax Court · 1985
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