Ginsburg v. Comm'r
United States Tax Court
A TEFRA partnership claimed losses from an investment. See Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, secs. 402-407(a), 96 Stat. 648. Ps reported the losses as shareholders of their two wholly owned S corporations, each of which owned a 50-percent interest in the partnership. R examined the Federal tax return of the partnership. Subsequently, R sent a letter to the representative for the partnership stating that R accepted the return as filed.
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A TEFRA partnership claimed losses from an investment. See Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, secs. 402-407(a), 96 Stat. 648. Ps reported the losses as shareholders of their two wholly owned S corporations, each of which owned a 50-percent interest in the partnership. R examined the Federal tax return of the partnership. Subsequently, R sent a letter to the representative for the partnership stating that R accepted the return as filed. The partnership and R executed six consecutive Forms 872-P, Consent to Extend the Time to Assess Tax Attributable to…
1Opinion of the Court
ALAN H. GINSBURG AND ESTATE OF HARRIET F. GINSBURG, DECEASED, ALAN H. GINSBURG, PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ginsburg v. Comm'r
No. 13330-05
United States Tax Court
127 T.C. 75; 2006 U.S. Tax Ct. LEXIS 24; 127 T.C. No. 5;
August 30, 2006, Filed
A TEFRA partnership claimed losses from an investment. See Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, secs. 402-407(a), 96 Stat. 648. Ps reported the losses
as shareholders of their two wholly owned S corporations, each
of which owned a 50-percent interest in the partnership. R
2Cases cited23 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Weinberger v. Hynson, Westcott & Dunning, Inc.Supreme Court of the United States · 1973
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
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