Legal Opinion

InverWorld, Ltd. v. Commissioner

United States Tax Court

Decided January 27, 1992No. Docket No. 27090-90Published

R issued two separate statutory notices (notice A and notice B) to P dated Sept. 7, 1990, relating to P's tax liability for 1984, 1985, and 1986. P timely filed a petition contesting R's determinations made in notice A. P attached to its petition notice A but not notice B. P did not specifically refer to notice B or dispute R's determinations contained therein in the petition.

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R issued two separate statutory notices (notice A and notice B) to P dated Sept. 7, 1990, relating to P's tax liability for 1984, 1985, and 1986. P timely filed a petition contesting R's determinations made in notice A. P attached to its petition notice A but not notice B. P did not specifically refer to notice B or dispute R's determinations contained therein in the petition. After the expiration of the period for filing a petition, P filed a motion for leave to file amendments to petition to contest the deficiencies and additions to tax determined in notice B. P and R agree that notice B…

1Opinion of the Court

InverWorld, Ltd., Petitioner v. Commissioner of Internal Revenue, Respondent

InverWorld, Ltd. v. Commissioner

Docket No. 27090-90

United States Tax Court

98 T.C. 70; 1992 U.S. Tax Ct. LEXIS 8; 98 T.C. No. 7;

January 27, 1992, Filed

An appropriate order will be issued.

R issued two separate statutory notices (notice A and notice B) to P dated Sept. 7, 1990, relating to P's tax liability for 1984, 1985, and 1986. P timely filed a petition contesting R's determinations made in notice A. P attached to its petition notice A but not notice B. P did not specifically refer to notice B or dispute R's…

2Cases cited9 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Normac, Inc. v. CommissionerUnited States Tax Court · 1988
  3. O'Neil v. CommissionerUnited States Tax Court · 1976
  4. Martz v. CommissionerUnited States Tax Court · 1981
  5. S-K Liquidating Co. v. CommissionerUnited States Tax Court · 1975

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