Cambridge Research & Dev. Group v. Commissioner
United States Tax Court
L and K were the general partners of a limited partnership during 1983. K resigned as general partner in 1984 and converted his interest in the partnership to that of a limited partner.
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L and K were the general partners of a limited partnership during 1983. K resigned as general partner in 1984 and converted his interest in the partnership to that of a limited partner. In 1986, L signed, on behalf of all partners, a Form 872-O consent to extend the period for assessing tax attributable to partnership items for 1983. L had authority under Connecticut law and a written partnership agreement to bind the partnership and its partners through execution of instruments. However, no separate writing specifically authorizing L to extend the period of limitations existed. Held: K, the…
1Opinion of the Court
OPINION
Halpern, Judge:*
In T.C. Memo. 1989-679 (Cambridge I), we denied petitioner’s motion to dismiss for lack of jurisdiction on the grounds that petitioner’s claim with regard to the statute of limitations did not present a jurisdictional issue but, rather, raised a defense in bar. Subsequently, the parties jointly moved that petitioner’s defense in bar be separated from any other issues and submitted without trial for decision. We granted those motions. Accordingly, the issue before us concerns the period of limitations for making assessments of tax. In particular, it concerns whether an…
2Cases cited4 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Amesbury Apartments, Ltd. v. CommissionerUnited States Tax Court · 1990
- Barbados 7 Ltd. v. CommmmissionerUnited States Tax Court · 1989
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1989
3Cited by21 opinions
- Monetary II Limited Partnership, J. Thomas Hannan, Tax Matters Partner v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Boyd v. CommissionerUnited States Tax Court · 1993
- AD Global Fund, LLC ex rel. North Hills Holding, Inc. v. United StatesUnited States Court of Federal Claims · 2005
- Madison Recycling Associates v. Commissioner Of Internal RevenueCourt of Appeals for the Second Circuit · 2002
- Bugaboo Timber Co. v. CommissionerUnited States Tax Court · 1993
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