Bedrosian v. Comm'r
United States Tax Court
Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. R issued an FPAA with respect to the partnership determining that the partnership was a sham. Ps did not file a timely petition. Ps claimed deductions for professional fees.
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Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. R issued an FPAA with respect to the partnership determining that the partnership was a sham. Ps did not file a timely petition. Ps claimed deductions for professional fees. R issued a notice of deficiency duplicating the partnership adjustments and also disallowing the deduction for professional fees. R filed a motion to dismiss asserting that we lack jurisdiction over the…
1Opinion of the Court
JOHN C. BEDROSIAN AND JUDITH D. BEDROSIAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bedrosian v. Comm'r
Docket No. 12341-05
United States Tax Court
144 T.C. 152; 2015 U.S. Tax Ct. LEXIS 10; 144 T.C. No. 10;
March 17, 2015, Filed
Bedrosian v. Comm'r, 143 T.C. 83, 2014 U.S. Tax Ct. LEXIS 35 (Aug. 13, 2014)
An appropriate order will be issued.
Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. R issued an FPAA with…
2Cases cited22 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
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