Greenberg Bros. P'ship 4 v. Commissioner
United States Tax Court
Pursuant to sec. 6224(c)(2), I.R.C., Ps request consistent settlement terms of partnership items with earlier settlement agreements that include concessions pertaining to partnership and nonpartnership items. HELD: A settlement agreement that includes concessions of partnership and nonpartnership items is not subject to the consistent settlement provisions under sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., 52 Fed.
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Pursuant to sec. 6224(c)(2), I.R.C., Ps request consistent settlement terms of partnership items with earlier settlement agreements that include concessions pertaining to partnership and nonpartnership items. HELD: A settlement agreement that includes concessions of partnership and nonpartnership items is not subject to the consistent settlement provisions under sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5, 1987). HELD, FURTHER: Sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., supra, is valid.
1Opinion of the Court
GREENBERG BROTHERS PARTNERSHIP #4, a.k.a. BREATHLESS ASSOCIATES, RICHARD M. GREENBERG, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. GREENBERG BROTHERS PARTNERSHIP #4, a.k.a. BREATHLESS ASSOCIATES, RICHARD M. GREENBERG, TAX MATTERS PARTNER, ET AL., 1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Greenberg Bros. P'ship #4 v. Commissioner
Tax Ct. Dkt. No. 19575-91. Docket Nos. 22780-91, 29878-91, 621-92, 623-92, 3968-92, 4432-92, 13014-92, 15641-92, 12062-94
United States Tax Court
111 T.C. 198; 1998 U.S. Tax Ct. LEXIS 42; 111 T.C. No. 7;
August…
2Cases cited37 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Morton v. RuizSupreme Court of the United States · 1974
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
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