Abatti v. Commissioner
United States Tax Court
The Commissioner issued statutory notices of deficiency to petitioners in which he "determined from the books and records of petitioners' partnership and subchapter S corporations that petitioners had additional income and losses in lieu of the amounts reported on the returns." The statutory notices did not incorporate by reference any revenue agents' reports.
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The Commissioner issued statutory notices of deficiency to petitioners in which he "determined from the books and records of petitioners' partnership and subchapter S corporations that petitioners had additional income and losses in lieu of the amounts reported on the returns." The statutory notices did not incorporate by reference any revenue agents' reports. The income and losses reported by petitioners on their returns coincided with petitioners' distributive shares reflected on the books and records and tax returns of the partnership and subchapter S corporations. At trial respondent…
1Opinion of the Court
TONY ABATTI and SHEILA GRUIS, formerly known as SHEILA ABATTI, et al/, 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Abatti v. Commissioner
Docket No. 6529-76, 6559-76, 6627-76, 4138-77, 4139-77.
United States Tax Court
T.C. Memo 1978-392; 1978 Tax Ct. Memo LEXIS 124; 37 T.C.M. (CCH) 1597; T.C.M. (RIA) 78392;
September 28, 1978, Filed
The Commissioner issued statutory notices of deficiency to petitioners in which he "determined from the books and records of petitioners' partnership and subchapter S corporations that petitioners had additional income and losses in lieu of the amounts…
2Cases cited35 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
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3Cited by2 opinions
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
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