Amesbury Apartments, Ltd. v. Commissioner
United States Tax Court
Amesbury is a limited partnership. Ballard Equity and Bowen Ballard have identical profit interests as the sole general partners of Amesbury. R issued an FPAA for the 1983 and 1984 taxable years to Amesbury. The FPAA was mailed to Amesbury on Mar. 30, 1988, at the partnership address, attn: Mr. Bowen Ballard, Tax Matters Partner, and copies were sent to the notice partners of Amesbury.
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Amesbury is a limited partnership. Ballard Equity and Bowen Ballard have identical profit interests as the sole general partners of Amesbury. R issued an FPAA for the 1983 and 1984 taxable years to Amesbury. The FPAA was mailed to Amesbury on Mar. 30, 1988, at the partnership address, attn: Mr. Bowen Ballard, Tax Matters Partner, and copies were sent to the notice partners of Amesbury. Two days after the close of the 90-day period following the issuance of the FPAA, Ballard Equity filed a petition with the Court (docket No. 16044-88), claiming to be the tax matters partner. Within 60 days…
1Opinion of the Court
OPINION
RUWE, Judge:
This case was heard by Special Trial Judge Lee M. Galloway pursuant to the provisions of section 7443A of the Code.1 This Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GALLOWAY, Special Trial Judge:
These consolidated cases are before the Court on the following motions filed by the parties:
1. Respondent’s motion to correct caption in docket No. 16044-88;
2. Respondent’s motion to dismiss duplicate petition in docket No. 22252-88;
3. Petitioner’s motion to dismiss for lack of jurisdiction in docket No.…
2Cases cited10 opinions
- Stange v. United StatesSupreme Court of the United States · 1931
- Adler v. CommissionerUnited States Tax Court · 1985
- Piarulle v. Comm'rUnited States Tax Court · 1983
- Robinson v. CommissionerUnited States Tax Court · 1972
- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
5 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Gustafson v. CommissionerUnited States Tax Court · 1991
- Mecom v. CommissionerUnited States Tax Court · 1993
- Monetary II Limited Partnership, J. Thomas Hannan, Tax Matters Partner v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
- Montana Sapphire Assoc., Ltd. v. CommissionerUnited States Tax Court · 1990
41 more not listed; retrieve them via the Exa API.